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Addressing the SEC’s New Cybersecurity Risk Management, Strategy, Governance and Incident Disclosure Requirements

In July 2023, the SEC adopted new cybersecurity rules for the stated purpose of enhancing and standardizing disclosures regarding cybersecurity risk management, strategy, governance and incidents by public companies. The...more

What is “Expedient” Notification of a “Data Breach?”

One of the first questions companies ask us when we are hired to help them respond to a new security incident is how fast they have to notify if the investigation shows that a “breach” occurred. Except for a couple of states...more

Proposed FFIEC Guidance on Financial Institution Social Media Use

The Federal Financial Institutions Examination Council (FFIEC) released for comment on January 17 its proposed Social Media: Consumer Compliance Risk Management Guidance. There is a 60-day comment period. The purpose of the...more

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