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Disclosure Requirements Securities and Exchange Commission (SEC) Risk Management

Kramer Levin Naftalis & Frankel LLP

SEC Provides Guidance on Liquidity Rule Compliance

On Aug. 28, 2024, the SEC issued a release providing guidance on certain aspects of open-end funds’ compliance with Rule 22e-4, i.e., the Liquidity Rule, under the Investment Company Act of 1940 (the Guidance). The Guidance...more

Society of Corporate Compliance and Ethics...

[Virtual Event] ESG and Compliance Conference - November 7th, 8:00 am - 5:00 pm CT

Stay on top of ever-evolving ESG requirements and emerging trends - With the SEC’s newly issued rules surrounding ESG disclosures and the continued growth of regulations rolling out in the EU, Canada, Asia and elsewhere...more

Perkins Coie

The SEC’s Climate Rules: Item 1502(e)’s Transition Plan Disclosure (Including Annual Progress)

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This is another in a series of blogs we will be posting breaking down the SEC’s new climate disclosure rules. We’re near the end of Regulation S-K Item 1502, Strategy. For the full text, see pages 852 through 855 of the...more

Jones Day

SEC v. SolarWinds: Court Rejects SEC Authority Over Cybersecurity Controls and Most Alleged Disclosure Violations

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The U.S. District Court for the Southern District of New York dismissed the majority of claims that the Security and Exchange Commission ("SEC") asserted against SolarWinds, including claims that the company's alleged...more

Cooley LLP

SEC Settles Charges Against RR Donnelley Related to Cybersecurity Incident Disclosure and Internal Access Controls

Cooley LLP on

On June 18, 2024, the Securities and Exchange Commission (SEC) announced that it had settled claims against RR Donnelley (RRD) related to a 2021 ransomware and cyber extortion attack. Despite RRD having discovered and...more

American Conference Institute (ACI)

The Road to Net Zero: Core Principles to Prevent Greenwashing

“Net zero” is a topic as hot as the climate these days. With so much regulatory attention being placed on it, companies that do not communicate their net zero efforts appropriately or, worse, intentionally make false and...more

Troutman Pepper

SEC Issues Additional Guidance Regarding Cybersecurity Incident Disclosure

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On June 24, the staff of the U.S. Securities and Exchange Commission's (SEC) Division of Corporation Finance (Division of Corporation Finance) released five new Compliance & Disclosure Interpretations (C&DIs) relating to the...more

Wyrick Robbins Yates & Ponton LLP

SEC Issues Additional Guidance on Form 8-K Cybersecurity Disclosures

The Securities and Exchange Commission (the “SEC”) has issued five compliance and disclosure interpretations related to the disclosure of material cybersecurity incidents under Item 1.05 of Form 8-K....more

Mintz - Privacy & Cybersecurity Viewpoints

SEC Issues Updated Guidance on Cybersecurity Incident Disclosure Under Item 1.05 of Form 8-K

On June 24, 2024, the SEC issued five new Compliance & Disclosure Interpretations (C&DIs) relating to the materiality assessment and disclosure requirements of material cybersecurity incidents under Item 1.05 of Form 8-K....more

Alston & Bird

SEC Corporation Finance Provides Additional Guidance on the Disclosure of Material Cybersecurity Incidents in Form 8-K

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On June 24, 2024, the Division of Corporation Finance (“Corp Fin”) of the Securities and Exchange Commission (“SEC”) issued five new Compliance and Disclosure Interpretations (“C&DIs”) related to the disclosure of “material”...more

Snell & Wilmer

Summer 2024 Corporate Communicator

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On March 6, 2024, the Securities and Exchange Commission (the “SEC”) adopted final climate disclosure rules (the “Final Rules”)1 to take effect as early as the beginning of the 2025 fiscal year. On April 4, 2024, the SEC...more

Holland & Knight LLP

SEC Cyber Enforcement Update: Which Way Are the SolarWinds Blowing?

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The SEC has been aggressively pursuing cybersecurity investigations and enforcement actions against public companies and foreign private issuers. In these actions, the SEC often alleges one of two theories: 1) that the...more

Woodruff Sawyer

Risk Mitigation for Asset Managers After the Demise of the Private Fund Adviser Rules

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While there is rest for weary legal and compliance pros at asset managers, and as you enjoy a cool Arnold Palmer in your hammock this Independence Day, spend a few minutes thinking about how your firm can leverage this moment...more

Mayer Brown Free Writings + Perspectives

SEC Announces New Cybersecurity Interpretations

The SEC’s Division of Corporation Finance yesterday published five new Compliance and Disclosure Interpretations, or “C&DIs,” all concerning Item 1.05 of Exchange Act Form 8-K, Disclosure of Cybersecurity Incidents....more

Wyrick Robbins Yates & Ponton LLP

Living in a Material World: SEC Clarifies Expectations Regarding Form 8-K Disclosure of Material Cybersecurity Incidents

Last month, the Director of the Division of Corporation Finance (“Director”) of the Securities and Exchange Commission (“SEC”) issued new guidance regarding disclosures of material cybersecurity incidents via Form 8-K under...more

Baker Donelson

[Webinar] New Privacy and Cybersecurity Regulations: What Financial Institutions Need to Know to Stay Compliant - June 13th, 10:00...

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The financial services industry has seen a litany of new data privacy and cybersecurity challenges through the first half of 2024. Financial institutions are facing unprecedented compliance hurdles resulting from the...more

A&O Shearman

New SEC guidance on cybersecurity incident disclosures

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The Director of the Division of Corporation Finance of the SEC issued a statement last week relating to the recent SEC cybersecurity disclosure rules that require public companies to disclose the occurrence of material...more

Wiley Rein LLP

Darned if You Do, Darned if You Don’t: Recent Lessons from the SEC On Cyber Reporting

Wiley Rein LLP on

The Security and Exchange Commission (SEC) Director of the Division of Corporate Finance, Erik Gerding, released a statement on May 21, 2024 that may have regulated entities scratching their heads about compliance and the...more

Holland & Knight LLP

SEC Corporation Finance Director Voluntarily Weighs in on Cybersecurity Incident Disclosures

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The U.S. Securities and Exchange Commission's (SEC) Division of Corporation Finance Director Erik Gerding released a statement on May 21, 2024, addressing Disclosure of Cybersecurity Incidents Determined to be Material and...more

Mayer Brown Free Writings + Perspectives

Avoiding Cybersecurity Incident Overdisclosure:  Helpful Guidance

In a statement yesterday, the Director of the SEC’s Division of Corporation Finance commented on the relatively new Form 8-K Item 1.05 requirement.  Last summer when the SEC adopted the final rules relating to cybersecurity...more

Stinson - Corporate & Securities Law Blog

SEC Director of Corporation Finance Speaks to Cybersecurity Disclosures

Erik Gerding, Director, Division of Corporation Finance, released a statement on the preferred methods to disclose certain cybersecurity incidents.  Mr. Gerding noted “The cybersecurity rules that the Commission adopted on...more

Skadden, Arps, Slate, Meagher & Flom LLP

Preparing Now for the SEC’s New Climate Rules

On March 6, 2024, the SEC adopted new rules mandating climate-related disclosures in public companies’ annual reports and registration statements. As anticipated, the rules are facing multiple legal challenges, which have...more

DarrowEverett LLP

The Heat Is On SEC’s Climate-Related Disclosure Rules

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On March 6, 2024, the U.S. Securities and Exchange Commission (the “SEC”) adopted new final rules requiring issuers to include extensive disclosure in registration statements and periodic reports regarding material...more

K&L Gates LLP

Carbon Quarterly – Volume 8

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Carbon Quarterly is a newsletter covering developments in carbon policy, law, and innovation. No matter your views on climate change policy, there is no avoiding an increasing focus on carbon regulation, resiliency planning,...more

SEC Compliance Consultants, Inc. (SEC³)

Top Tips for Updating Your 2024 Compliance Program

Every year compliance officers face the unenviable job of performing their compliance program's annual review under Advisers Act Rule 206(4)-7). An essential element of that review is updating the firm's compliance policies...more

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