Timothy Blank

Timothy Blank

Dechert LLP

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Latest Publications


NFA Adopts Cybersecurity Guidance

The National Futures Association (NFA) adopted on October 23, 2015 an “Interpretive Notice to NFA Compliance Rules 2-9, 2-36, and 2-49: Information Systems Security Programs” (Notice). The Notice requires each NFA Member to...more

11/6/2015 - Brokers CFTC Commodity Pool CPOs CTA Cybersecurity Dealers Employee Training Information Systems Security Program (ISSP) Major Swap Participants National Futures Association NFA Parent Corporation Popular Recordkeeping Requirements Risk Assessment SEC Swap Dealers Third-Party Service Provider

Global Private Equity Newsletter - Fall 2015 Edition: Evaluating Cybersecurity Risks and Preparedness in Target Companies

Before committing resources to a potential investment, private equity firms should aggressively evaluate a target company’s cyber risks and cyber preparedness. Some target companies are naturally more exposed to cyber risk...more

10/12/2015 - CISO Cyber Insurance Cybersecurity Data Collection Data-Sharing FTC Global Marketplace Incident Response Plans Information Security Popular Privacy Notice Rule Privacy Policy Private Equity Risk Assessment Target Company WISP

SEC Cybersecurity Examinations and Enforcement: What Broker-Dealers and Investment Advisers Need to Know

The Securities and Exchange Commission’s (SEC or Commission) Office of Compliance Inspections and Examinations (OCIE) announced in a September 15, 2015 Risk Alert (2015 Risk Alert) that it will be conducting a second round of...more

9/29/2015 - Broker-Dealer Cybersecurity Enforcement Industry Examinations Investment Adviser OCIE SEC

U.S. SEC Division of Investment Management Issues Cybersecurity Guidance

The Division of Investment Management (Division) of the U.S. Securities and Exchange Commission (SEC) issued a Guidance Update on April 28, 2015 (Guidance) relating to the cybersecurity of registered investment companies and...more

5/19/2015 - Cybersecurity Guidance Update Investment Adviser Investment Firms SEC

The Evolving U.S. Cybersecurity Landscape: What Firms Want to Know

Following a year of high-profile data breaches, the Securities and Exchange Commission (SEC) announced on January 13, 2015 that, for the second consecutive year, its Office of Compliance Inspections and Examinations (OCIE)...more

4/17/2015 - Cybersecurity Data Breach Federal Breach Notification Standard Industry Examinations Information Sharing NCCIC Obama Administration OCIE SEC Third-Party

President Obama Issues New Executive Order Authorizing Sanctions Against Cyber Attackers

President Obama issued an Executive Order (the “Order”) on April 1, 2015 that authorizes financial sanctions against certain “persons” (including both individuals and entities) designated by the Treasury Secretary to be...more

4/8/2015 - Barack Obama Cyber Attacks Cybersecurity Executive Orders Sanctions SDN List U.S. Treasury

SEC Staff to Conduct Broker-Dealer and Investment Adviser Examinations Focused on Cybersecurity

The Securities and Exchange Commission’s (the “SEC” or the “Commission”) Office of Compliance Inspections and Examinations (“OCIE”) announced in an April 15, 2014 Risk Alert (the “Alert”) that it will be conducting...more

4/22/2014 - Cybersecurity Data Protection Investment Adviser OCIE SEC

Court Sides with FTC on Sweeping Data Security Role

Executive Summary: Federal Trade Commission v. Wyndham Worldwide Corp. A U.S. District Court has ruled this week that the Federal Trade Commission (FTC) has authority under Section 5 of the FTC Act to bring enforcement...more

4/9/2014 - Cybersecurity Data Protection FTC Wyndham

SEC and CFTC Issue Identity Theft Red Flags Rules Applicable to Financial Institutions and Creditors

The SEC and CFTC recently issued joint Identity Theft Red Flags Rules (the “Rules”), which are rules and guidelines requiring certain financial institutions worldwide to adopt comprehensive data security programs to detect...more

4/30/2013 - Broker-Dealer CFTC CPO Data Protection FCMs FCRA Identity Theft Investment Adviser Red Flags Rule SEC

Cybersecurity Disclosure: The Risks Of Silence

With the rise in targeted, sophisticated, malicious attacks on corporate America’s electronic infrastructure, companies are increasingly focused on their cybersecurity disclosure obligations. There is a growing concern that...more

3/11/2013 - Cybersecurity Data Breach Data Protection Disclosure Requirements SEC

White House Issues Executive Order on CyberSecurity

The Obama Administration has long expressed concerns about the vulnerability of America’s critical infrastructure to cyber-attack. On February 12, 2012, the day of the President’s State of the Union address, the...more

3/1/2013 - Barack Obama Critical Infrastructure Sectors Cybersecurity Cybersecurity Framework DHS Executive Orders Fair Information Practice Principles Information Sharing Infrastructure NIST OMB

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