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The SEC’s Proposed New Cybersecurity Disclosure Requirements: ABS Supplement for Asset-Backed Issuers

Last week, the SEC proposed new disclosure rules for public companies regarding cybersecurity incidents and related policies and procedures.  These rules could affect how companies structure cybersecurity programs....more

OCC and FDIC Successfully Defend Valid-When-Made Rules

The Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) have successfully defended their respective valid-when-made rules. On February 8, 2022, Judge Jeffry S. White, U.S....more

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