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Publicly-Traded Companies Incident Response Plans Securities and Exchange Commission (SEC)

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...

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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

Holland & Knight LLP

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

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This Holland & Knight blog post is the second installment in a two-part series that examines the challenges to the U.S. Securities and Exchange Commission's (SEC) charges in its landmark case against SolarWinds Corp....more

BCLP

SDNY Dismisses Majority of SEC Landmark Charges Against SolarWinds and CISO

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On July 18, 2024, District Court Judge Engelmayer of the Southern District of New York issued his 107-page opinion and order dismissing most – but not all – of the landmark allegations of the SEC against SolarWinds Corp. and...more

Parker Poe Adams & Bernstein LLP

Key Lessons for Cybersecurity and IT Leaders From Judge's Recent Fraud Decision in SEC Case Against SolarWinds

On July 18, a New York federal judge threw out most of the SEC’s claims brought against both SolarWinds Corp. and the company’s chief information security officer (CISO), Timothy Brown....more

Clark Hill PLC

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

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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

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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

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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

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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

Mintz - Privacy & Cybersecurity Viewpoints

SEC Adopts Final Cybersecurity Rules for Public Companies

In a narrow 3-2 decision on July 26, the SEC adopted its final rule concerning cybersecurity risk management, strategy, governance, and incident disclosure (the “Final Rule”).  Below we highlight some of the principal changes...more

Jenner & Block

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

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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

Paul Hastings LLP

SEC Proposed Cybersecurity Rules – What They Are and What Our Clients Should be Doing Now

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What are the new rules? Earlier this year, the Securities and Exchange Commission (“SEC”) published a new set of proposed cybersecurity disclosure rules for public companies. The proposed rules would significantly increase...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

Keating Muething & Klekamp PLL

Proposed SEC Cybersecurity Rules

On March 9, 2022, the Securities and Exchange Commission (“SEC”) proposed amendments to rules to expand and standardize disclosures regarding cybersecurity risk management, strategy, governance, and incident reporting by...more

Goodwin

SBA Implemented Changes to PPP as a Part of American Rescue Plan Act

Goodwin on

In this Issue. The federal bank regulatory agencies announced that the temporary change to the supplementary leverage ratio for depository institutions will expire as scheduled on March 31, 2021; the Small Business...more

Dechert LLP

OCIE Cyber Risk Alert Identifies Increase in Sophistication of Ransomware Attacks on SEC Registrants

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The Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) issued a cybersecurity risk alert on July 10, 2020 regarding ransomware (Alert). In the Alert, OCIE described “recent reports”...more

Sheppard Mullin Richter & Hampton LLP

Buyers (And Sellers) Beware!: SEC Observations on Cybersecurity and Resiliency

The Securities and Exchange Commission recently published a set of observations designed to assist financial market participants. While not legally binding, the observations are guideposts for investment companies, securities...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

Dechert LLP

2020/02/13 OCIE Releases 2020 Cybersecurity Observations

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The Office of Compliance Inspections and Examinations of the Securities and Exchange Commission released cybersecurity and resiliency-related examination observations on January 27, 2020, based on “thousands of examinations...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Investigative Report on Cybersecurity Emphasizes Internal Controls

On October 16, 2018, the Securities and Exchange Commission (SEC) issued a Report of Investigation (Report) detailing an investigation by the SEC’s Enforcement Division into the internal accounting controls of nine issuers...more

Dechert LLP

SEC 2018 Examination Priorities Match Chairman Clayton’s Priorities as Reflected in the Agency’s Budget Request

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This year’s examination priorities of the Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission (SEC) were announced on February 6, 2018, and cover five broad, albeit...more

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