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SEC Returns Spotlight to Cybersecurity Disclosure Enforcement

On June 15, the Securities and Exchange Commission announced a settlement with First American Financial Corporation for what the SEC found were inadequate disclosure controls and procedural violations, revealed in connection...more

Widening the Aperture Beyond Retail-Focused Advisers

SEC Enforcement and Exams Likely to Focus More on Private Funds in the New Administration - For the next several weeks and months, intense focus will be trained on determining the priorities of the Biden administration. We...more

SEC Examiners Warn of COVID-Related Compliance Risks for Broker-Dealers and Investment Advisers

The Securities and Exchange Commission (“SEC”) last week published its observations from the first five months operating the SEC’s national examination program during the ongoing COVID-19 pandemic. This is the latest...more

Quarantine Your Sensitive Business Information to Avoid Inadvertent Tipping Liability

If you are reading this during April 2020, you’re probably reading it from somewhere in your own home — and probably near the friends and loved ones with whom you’re living in close quarters during this time of remote work,...more

SEC Investigative Report Warns Public Companies To Prioritize Cybersecurity In Their Accounting Controls

On October 16, 2018, the U.S. Securities and Exchange Commission (“SEC”) issued an investigative report advising public companies that internal accounting controls should “reasonably safeguard company and, ultimately,...more

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