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SEC Releases Interpretations on Ransomware Attacks and Payment Disclosures

The US Securities and Exchange Commission (SEC), Division of Corporation Finance on June 24, 2024 issued five Compliance and Disclosure Interpretations (C&DIs) on its website to address questions raised by its requirement for...more

SEC’s New Data Breach Requirement Increases Obligations for Financial Services Companies

The US Securities and Exchange Commission has adopted amendments to Regulation S-P requiring entities under its remit to provide notice to individuals affected by certain types of data breaches. This adds yet another...more

How Financial Services Companies Can Prepare for and Comply with New Federal Cybersecurity Requirements

US regulators have increased their focus on cybersecurity issues impacting financial services companies, with a host of guidance documents recently released by the US Securities and Exchange Commission (SEC), the three...more

SEC Proposes Cybersecurity Incident Reporting and Broker-Dealer Cyber Risk Management Requirements

The US Securities and Exchange Commission (SEC) issued a notice of proposed rulemaking (the Proposal) on March 15 that would require SEC-regulated investment advisers, investment companies, and broker dealers to provide...more

SEC Proposes Cybersecurity Risk Management Rules for Advisers and Funds

The US Securities and Exchange Commission (SEC) recently proposed a comprehensive framework of cybersecurity-related rules and amendments for investment advisers and investment companies. Although advisers and funds may have...more

Federal Banking Agencies Adopt New Computer-Security Incident Notification Requirements

The three federal banking agencies (i.e., the Federal Reserve Board, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency—collectively, the Agencies) published a final rule (the Rule)...more

Expanded Safeguards Rule Applicable to More Financial Institutions; Gives More Specificity on Security Requirements

The Federal Trade Commission recently finalized a long-discussed update to its cybersecurity Safeguards Rule that includes more specific criteria for what financial institutions must implement as part of their information...more

Update: Security Requirements under New York SHIELD Act to Go Into Effect

One of the major changes introduced by the Stop Hacks and Improve Electronic Data Security (SHIELD) Act, which was signed into New York law last year, is scheduled to take effect this week. ...more

The Government’s Role in Promoting and Leading Effective Cybersecurity

Introduction - Data breaches have the power to inflict significant damage and consequences with the potential to bring a company, industry or government agency to its knees, or adversely harm those individuals whose...more

SEC Observations from Recent Cybersecurity Examinations Identify Best Practices

The SEC continues to focus on cybersecurity as an area of concern within the investment management industry....more

WannaCry Ransomware Cyberattack Raises Legal Issues

The recent cyberattack highlights the need for firms to engage in proactive prevention and protection. Ransomware (malware that encrypts data pending an extortion payment) is a recurring cyber threat that is growing more...more

Morgan Lewis Urges NYDFS to Modify Its Re-Proposed Cybersecurity Rules

Morgan Lewis submits second comment letter on the proposed rules. The New York State Department of Financial Services (DFS) is expected soon to issue “first-in-the-nation” cybersecurity regulations that will apply to...more

NYDFS Modifies, Delays Implementation of Cybersecurity Rules

The modified rules, which still remain among the most prohibitive, could be adopted in final form as early as this month. Since September 2016, the New York State Department of Financial Services (DFS) has been...more

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