Threat actors are evolving. Our Privacy, Cyber & Data Strategy Team explains how ransomware gangs have changed their tactics and how companies can respond to the threat while navigating new scrutiny from investors and...more
2/26/2024
/ Corporate Counsel ,
Cyber Attacks ,
Cyber Crimes ,
Cyber Threats ,
Cybersecurity ,
Data Breach ,
Data Protection ,
Data Security ,
Data Theft ,
NYDFS ,
Popular ,
Ransomware ,
Reporting Requirements ,
Risk Management ,
Securities and Exchange Commission (SEC)
With an amendment to its Safeguards Rule, the Federal Trade Commission has joined other federal agencies regulating cybersecurity breaches. Our Privacy, Cyber & Data Strategy Team analyzes how the amendment will affect...more
The New York Department of Financial Services (“NY DFS”) published an updated proposed Second Amendment to its Cybersecurity Regulation (23 NYCRR Part 500) in the New York State Register on June 28, 2023, updating its...more
The National Association of Insurance Commissioners (NAIC) Privacy Protections Working Group (the “Working Group”) released Insurance Consumer Privacy Protection Model Law #674 (“Model 674”) for comment on February 1, 2023....more
The New York Department of Financial Services (“DFS”) released their proposed second amendment to the Cybersecurity Regulation, 23 NYCRR Part 500 (“Proposed Second Amendment”) on October 9, 2022....more
On September 20, 2022, the Securities and Exchange Commission (SEC) settled an enforcement action with a large, registered investment adviser (the Firm) for alleged violations of the Safeguards Rule and the Disposal Rule of...more
On July 27, 2022, the Securities and Exchange Commission (SEC) separately settled three enforcement actions with broker-dealers and investment advisers for alleged deficiencies relating to the prevention of customer identity...more
Maryland recently passed House Bill 962, amending Maryland’s Personal Information Protection Act (PIPA) (Md. Code Ann. Comm. Law 14-3504). As summarized below, House Bill 962 amends certain aspects of PIPA relating to breach...more
The New York Department of Financial Services (NYDFS) continues to refine its position regarding the importance of and requirements regarding Multi-Factor Authentication (MFA), as evidenced most recently with the release of...more
Entities registered with the U.S. Securities & Exchange Commission (SEC) must maintain certain books and records and can be subject to the SEC’s examination, inspection, and enforcement authority. Responding to SEC requests...more
The New York Department of Financial Services (NYDFS) issued new guidance this week intended to assist organizations in thwarting ransomware attacks. The guidance clarifies the NYDFS’ expectation that NYDFS-regulated...more
Against the backdrop of the disruptions associated with the Covid-19 pandemic and SolarWinds cyber-espionage campaign, NYDFS has released guidance for insurers that underwrite cyber insurance policies and which contains a...more
2/19/2021
/ Cyber Attacks ,
Cyber Crimes ,
Cyber Insurance ,
Cybersecurity ,
Data Breach ,
Data Protection ,
Information Technology ,
NYDFS ,
Popular ,
Ransomware ,
Risk Management
Cybersecurity incidents—including second wave attacks—are on the rise. Our Privacy, Cyber & Data Strategy Team outlines seven tips for managing a cybersecurity incident—and recovering with strength....more
On January 28, 2020, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) released a detailed set of observations culled from thousands of examinations of registered investment advisers, broker-dealers,...more
Our Cybersecurity Preparedness & Response Team breaks down the ways in-house counsel can demonstrate compliance with the California Consumer Privacy Act to regulators and business partners....more
As independent auditors to public companies and business development companies begin to make required disclosure of Critical Audit Matters (CAMs) to the audit committee, such reports are beginning to include discussion of...more
The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) has issued a Risk Alert that provides an overview of the most common deficiencies or weaknesses in investment adviser and broker-dealer compliance with the...more
4/19/2019
/ Broker-Dealer ,
Cybersecurity ,
Data Protection ,
Data Security ,
Investment Adviser ,
OCIE ,
Policies and Procedures ,
Popular ,
Regulation S-P ,
Risk Alert ,
Securities and Exchange Commission (SEC)
The February 15, 2019 NYDFS compliance certification deadline represents the last annual compliance certification subject to the transition period for covered entities to come into compliance with the cybersecurity...more
On December 28, 2018, the Department of Health and Human Services (HHS) issued new voluntary cybersecurity guidance for the health care industry titled, “Health Industry Cybersecurity Practices: Managing Threats and...more
The Securities and Exchange Commission issued an investigative report last week cautioning public companies to consider cyber incidents and threats when implementing internal accounting controls. ...more
September 4, 2018 marks the end of the transitional period for covered entities to comply with several key provisions of the NYDFS Cybersecurity Requirements that require certain systemic and sustained measures....more
Investment advisers and broker-dealers can expect more scrutiny of their data security from the Securities and Exchange Commission. Our Cybersecurity Preparedness & Response and Investment Management, Trading & Markets teams...more