News & Analysis as of September 21, 2024

Cybersecurity › Information Systems Security Program (ISSP)

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Follow this channel for advisories on one of the biggest threats to businesses today. Read a morning brief of fresh guidance and commentary by leading lawyers on security, privacy, risk... more +

Follow this channel for advisories on one of the biggest threats to businesses today. Read a morning brief of fresh guidance and commentary by leading lawyers on security, privacy, risk management, global regulations, data protection, leaks, hacking, cyber insurance, compliance, HIPAA, and every other aspect of cybersecurity of import to corporate readers right now. less -

Complying With the FTC's Amended Safeguards Rule

Bradley Arant Boult Cummings LLP on 6/7/2023

Cybersecurity is a looming threat for most businesses. The impact of a major cyber event can resonate for weeks, months, and even years after the initial attack. To mitigate the risks to consumers, there have been several...more

What Does the Internet Of Things (IoT) Cybersecurity Improvement Act Mean For Government Contractors?

Husch Blackwell LLP on 12/16/2020

On December 4, 2020 the President signed into law the IoT Cybersecurity Improvement Act of 2020, Pub. L. No. 116-207 (the “IoT Act”). The legislative purpose behind the new law is to ensure the highest level of cybersecurity...more

Financial Firms Beware: Dangers Lurk in the Cloud

Latham & Watkins LLP on 11/26/2019

US regulators are calling attention to financial firms’ obligations to protect against evolving cybersecurity threats. On October 2, 2019, the Financial Industry Regulatory Authority (FINRA) issued an information notice to...more

CFTC Settlement Asserts Data Breach Disclosure Requirement for Future Commission Merchants

Akin Gump Strauss Hauer & Feld LLP on 10/14/2019

On September 12, 2019, the Commodity Futures Trading Commission (CFTC) announced a settlement with Phillip Capital Inc. (PCI or the “Company”), a registered futures commission merchant (FCM), after hackers successfully...more

January’s Privacy Blizzard

Eversheds Sutherland (US) LLP on 2/5/2019

As predicted, the start of 2019 provided scant respite from the frenetic pace of privacy and cybersecurity developments during 2018. This past month alone, in a blizzard of activity, regulators amended regulations and...more

Update to the NFA’s ISSP training, approval and notice requirements

Eversheds Sutherland (US) LLP on 1/31/2019

On January 7, 2019, the National Futures Association (NFA) issued an amendment to its Interpretive Notice on required Information Systems Security Programs (ISSPs) for NFA Members. ISSPs are required by the NFA so that NFA...more

NFA’s Amended Cybersecurity Guidance Includes New Incident Reporting Requirement

BakerHostetler on 1/17/2019

Following other regulators, the National Futures Association (NFA) recently amended its cybersecurity guidance to, among other things, impose a new cybersecurity incident reporting requirement on members....more

NFA Issues Interpretive Notices for CPOs Regarding Internal Controls Systems and Cybersecurity

Akin Gump Strauss Hauer & Feld LLP on 1/15/2019

• The NFA has determined that registered CPOs must implement an internal controls system and highlighted best practices for such a framework. • In response to certain frequently asked questions, the NFA has also updated its...more

NFA Proposes Interpretive Notice Addressing CPO Internal Controls

K&L Gates LLP on 1/4/2019

Introduction - By letter dated December 10, 2018, the National Futures Association (“NFA”), the self-regulatory organization for the U.S. derivatives industry, submitted to the U.S. Commodity Futures Trading Commission...more

Who Is Watching The Watchmen?: CFTC Penalizes Registrant For Outsourced IT Security Lapses

Bracewell LLP on 3/13/2018

On February 12, 2018, the Commodity Futures Trading Commission (CFTC) settled charges against AMP Global Clearing LLC (AMP), a futures commission merchant (FCM), for the company’s failure to adequately supervise one of its IT...more

DoD Issues Guidance for Compliance with Cybersecurity Regulations

Holland & Knight LLP on 10/9/2017

• In recently released guidance, the U.S. Department of Defense (DoD) confirms a "one size does not fit all" approach to contractor compliance with its cybersecurity clauses that cover the safeguarding of contractor networks,...more

DSS Revises Cybersecurity Requirements for Contractors Handling Classified Information

Holland & Knight LLP on 6/21/2016

On May 18, 2016, Department Security Service (DSS) recently approved Change 2 (Change 2) to the National Industrial Security Program Operating Manual (NISPOM). Change 2 significantly revised Chapter 8 of the NISPOM relating...more

NFA Issues Notice Regarding Cybersecurity Self-Examination Questionnaire

Katten Muchin Rosenman LLP on 3/8/2016

On February 29, National Futures Association (NFA) issued Interpretive Notice I-16-10, which notifies member firms about the addition of a cybersecurity section to NFA’s Self-Examination Questionnaire. This section is...more

CFTC Intermediaries to Adopt and Implement Cybersecurity Programs by March 1, 2016

Eversheds Sutherland (US) LLP on 3/1/2016

Commencing March 1, 2016, all commodity pool operators, commodity trading advisors, futures commission merchants, retail foreign exchange dealers, investment brokers, major swap participants and swap dealers that are National...more

NFA Adopts Cybersecurity Guidance for NFA Members

McGuireWoods LLP on 11/20/2015

On October 23, 2015, the National Futures Association (NFA) adopted its Interpretive Notice Regarding Information Systems Security Programs (the Notice). As noted in our prior Password Protected update, the Notice requires...more

NFA Adopts Cybersecurity Guidance

Dechert LLP on 11/6/2015

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

CFTC Approves NFA Interpretive Notice on Information Systems Security Programs, Including Cybersecurity Guidance

Foley Hoag LLP - Security, Privacy and the... on 10/30/2015

The CFTC recently approved the National Futures Association’s interpretive notice (the “Cybersecurity Notice”) on the general requirements that members should implement for their information systems security programs...more

SEC Cybersecurity Update

Proskauer on Privacy on 10/20/2015

Results from the SEC’s First Round of Cybersecurity Examinations - On February 3, 2015, the OCIE published a risk alert summarizing its findings from its examinations of over 100 registered investment advisers and...more

Four Cybersecurity Ideas from CFTC Commissioner Bowen

McGuireWoods LLP on 9/25/2015

On Sept. 17, 2015, Commissioner Sharon Y. Bowen of the U.S. Commodity Futures Trading Commission (CFTC) gave the keynote address for the International Swaps and Derivatives Association’s 2015 North American Conference in New...more

Cybersecurity Update: National Futures Association Proposes Cybersecurity Guidance Setting Forth General Requirements for Member...

K&L Gates LLP on 9/10/2015

The National Futures Association (“NFA”) submitted to the Commodity Futures Trading Commission (“CFTC”) on August 28, 2015 a proposed Interpretive Notice (“Proposed Guidance”) for CFTC’s approval, which provides guidance to...more

NFA Proposes Interpretive Notice on Information Systems Security Programs

Katten Muchin Rosenman LLP on 9/9/2015

On August 28, the National Futures Association (NFA) proposed the adoption of an interpretive notice that requires every NFA member firm to establish and enforce an information systems security program (ISSP). The proposed...more

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Cybersecurity › Information Systems Security Program (ISSP)

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