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SEC Settles Charges for Alleged Misleading Disclosures, Shedding Light on Materiality in Cyber Context

On Oct. 22, 2024, the Securities and Exchange Commission (SEC) announced settled charges against four current and former public companies, Unisys, Avaya Holdings, Check Point Software Technologies and Mimecast, for allegedly...more

SEC Adopts Cybersecurity Risk Management Strategy Governance Incident Disclosure Rules

On March 9, 2022, the U.S. Securities and Exchange Commission (SEC) released proposed rules regarding public companies’ reporting of (i) cybersecurity incidents, (ii) policies and procedures for identifying and managing...more

SEC Proposes New, Formal Cybersecurity Disclosure Rules

On March 9, 2022, the U.S. Securities and Exchange Commission (SEC) proposed a number of new rules to enhance public companies’ reporting of (i) cybersecurity incidents, (ii) their policies and procedures for identifying and...more

Between a Rock and a Hard Place: SEC Disclosure Analysis in Light of Yahoo Settlement

On April 25, the Securities and Exchange Commission announced a settlement with Yahoo that constituted its first enforcement action against a public company for failing to disclose a data breach. This settlement...more

New SEC Cybersecurity Guidance Outlines Disclosure Obligations

Last week, as previously reported, the U.S. Securities and Exchange Commission (SEC) unanimously voted to approve additional guidance for reporting cybersecurity risks. The release of this guidance underscores the SEC’s...more

Through the Wire: SEC Turns its Sights on Insider Trading, Hacking and Data Thievery

There once existed a time when a crew of skydiving surfers could throw on surprisingly well crafted ex-president masks, stroll into a cash-heavy bank and rob the institution blind. There was a time when the weapon of choice...more

SEC’s OCIE Issues a Second Cybersecurity Risk Alert

On Sept. 15, 2015, the Securities Exchange Commission (SEC) Office of Compliance Inspections and Examinations (OCIE) published its second cybersecurity risk alert (the “2015 Risk Alert”). The 2015 Risk Alert is a follow up to...more

SEC Division of Investment Management Issues Cybersecurity Guidance for Investment Funds and Advisers

The U.S. Securities and Exchange Commission’s (“SEC”) Division of Investment Management (“Division”) recently released a Guidance Update (“Guidance”) highlighting the importance of cybersecurity for registered investment...more

How Does Your Firm Compare? Results from the SEC’s Cybersecurity Examinations

On Feb. 3, 2015, the Securities and Exchange Commission (SEC) published a Risk Alert summarizing observations gleaned from a cybersecurity examination sweep of 57 registered broker-dealers (BDs) and 49 registered investment...more

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