News & Analysis as of

Publicly-Traded Companies Incident Response Plans Cyber Incident Reporting

Society of Corporate Compliance and Ethics...

The SEC’s cybersecurity and disclosure rules: The questions compliance pros still have

The U.S. Securities and Exchange Commission (SEC) Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure rules officially went into effect in December 2023. Aimed at improving cybersecurity risk...more

Robinson+Cole Data Privacy + Security Insider

Four Companies Settle Allegations of Deceptive Cyber Disclosures with SEC

This week, the Securities and Exchange Commission (SEC) charged four public companies for alleged deceptive cyber disclosures: Unisys Corp., Avaya Holdings Corp., Check Point Software Technologies Ltd., and Mimecast Limited....more

Troutman Pepper

SEC Cybersecurity Incidents Disclosures: Materiality, Decryptors, and Ransom Payments - Dear Mary – Incidents + Investigations...

Troutman Pepper on

I work for a public company that recently experienced a ransomware attack. Fortunately, we were able to restore our business operations quickly by obtaining a decryption key from the threat actor. Given that we managed to get...more

Clark Hill PLC

[Webinar] Practical Advice on the SEC Rule: Cybersecurity Incidents and Risk Management Disclosures - January 25th, 10:00 am PT

Clark Hill PLC on

Are you prepared for the new SEC Rule on Cybersecurity Incident and Risk Management Disclosures? Don't let your business get caught off guard! This webinar will cover important points about the rule and how to effectively...more

Goodwin

Cybersecurity - Cracking the Code on Upcoming Disclosures

Goodwin on

As annual reporting season begins, it is important to take a fresh look at the company’s governance and incident response processes and develop risk-informed and compliant disclosures. While many companies are understandably...more

Paul Hastings LLP

SEC Speech on Cybersecurity Disclosure

Paul Hastings LLP on

On December 14, 2023, Erik Gerding, Director, Division of Corporation Finance at the Securities and Exchange Commission (“SEC”) gave a speech on the SEC’s final rules (the “Final Rule(s)”) regarding cybersecurity risk...more

BCLP

Pressure-Testing Your Privacy Program for 2024

BCLP on

With the onslaught of new privacy legislation and cyber threats coupled with upticks in enforcement, running a well-functioning and flexible privacy program is now, more than ever, a critical component of an organization’s...more

Skadden, Arps, Slate, Meagher & Flom LLP

FBI, DOJ and SEC Publish Guidance on Requesting Delayed Reporting of Material Cyber Incidents on Form 8-K: Takeaways for CISOs and...

The U.S. Securities and Exchange Commission (SEC) adopted final rules in 2023 that are intended to enhance and standardize disclosures regarding cybersecurity risk management, strategy, governance and incident reporting by...more

Baker Donelson

Show Your Work: The SEC Cyber Rules and Documenting Materiality Analysis Under NIST FIPS 199

Baker Donelson on

The date July 26, 2023, marks the latest evolution of the cybersecurity regulation landscape as the Securities and Exchange Commission passed cybersecurity regulations for publicly traded companies. At the open meeting, SEC...more

Ankura

[Webinar] SEC New Cybersecurity Final Rule: A Different Perspective from the Viewpoints of the CISO, General Counsel, & The Board...

Ankura on

Any time a regulation is put forth, there is always a level of uncertainty, especially regarding understanding the roles and responsibilities of key business leaders. The SEC’s new cybersecurity final rule means heightened...more

Jenner & Block

Client Alert: SEC’s Approach to Enforcement After Cyber Incidents: Key Takeaways for Public Companies from a Recent Speech

Jenner & Block on

Last month, Gurbir Grewal, the Director of the SEC’s Division of Enforcement, spoke at the Financial Times Cyber Resilience Summit. During the remarks, he outlined the importance of cybersecurity and signaled that the SEC is...more

McDermott Will & Emery

[Webinar] Regulators Mount Up! Recent Developments in Government Oversight of Cybersecurity - October 11th, 12:00 pm - 1:00 pm EDT

McDermott Will & Emery on

Government agencies at the state and federal levels are increasingly training their sights on the cybersecurity resiliency of companies in an array of industries. The US Securities and Exchange Commission has proposed rules...more

Bass, Berry & Sims PLC

SEC Staff Comments on Chegg’s Data Breach Disclosure and Response; A Real Life Example

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One thing I appreciate about the SEC comment letter process is that it gives real life examples to what is often discussed hypothetically. Take, for example, cybersecurity and steps management should take when a data incident...more

Robinson+Cole Data Privacy + Security Insider

New York Stock Exchange releases cybersecurity guide for public companies

We continue to urge CEOs and boards of public companies (and private and not-for profits) to harken the call of getting a handle on cybersecurity risk to companies today. Not too soon, the New York Stock Exchange published a...more

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