News & Analysis as of

Covered Entities Reporting Requirements

Davis Wright Tremaine LLP

Deadline Approaching: Covered Entities Must File Certifications of Compliance With Amended NYDFS Cyber Regulation by April 15

In November 2023, the New York Department of Financial Services (NYDFS) issued its second amendment to its "Cybersecurity Requirements for Financial Services Companies (the Cybersecurity Regulation or Part 500). This was the...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Reminder: New York Cybersecurity Reporting Deadline April 15, 2025; New Regulations Effective May 1, 2025

Covered entities regulated by the New York State Department of Financial Services (NYDFS) must submit cybersecurity compliance forms by April 15, 2025. New sets of requirements for system monitoring and access privileges,...more

Katten Muchin Rosenman LLP

NYDFS Annual Compliance Submissions Due April 15, 2025 and New Compliance Requirements Effective on May 1, 2025

As we previously reported, in 2023 the New York State Department of Financial Services (NYDFS) amended its cybersecurity regulation, 23 NYCRR 500 (or Part 500). As of November 1, 2024, Class A Companies and Covered Entities...more

Orrick, Herrington & Sutcliffe LLP

NYDFS reminds covered entities to submit notifications by April 15

On February 27, NYDFS reminded covered entities subject to the Cybersecurity Regulation to submit their annual compliance notifications for the 2024 calendar year. Covered entities must submit the compliance filing by April...more

BCLP

Corporate Transparency Act Update: FinCEN Asks SCOTUS to Intervene

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As previously reported, on December 26, 2024, the Fifth Circuit first lifted—and then reinstated—a preliminary nationwide injunction staying the Corporate Transparency Act’s (“CTA”) reporting requirements pending appeal....more

Hinch Newman LLP

DOJ Issues Rule Addressing Threat Posed by Foreign Adversaries’ Access to Americans’ Sensitive Personal Data

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On Friday, December 27, 2024, the Justice Department issued a final rule to address “urgent national security risks posed by access to U.S. sensitive personal and government-related data from countries of concern and covered...more

BCLP

California Amends Its Sweeping Venture Capital Demographic Reporting Rule

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Last year, as we previously reported, California Governor Newsom signed into law Senate Bill 54, Fair Investment Practices by Investment Advisers, which requires “covered entities,” defined as a “venture capital company” that...more

Vinson & Elkins LLP

Proposed Cybersecurity Regulation Uncertain Under Trump Administration

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Proposed cybersecurity regulation may face changes or challenges in view of the incoming Trump administration that is intent on reducing the perceived regulatory burden on American companies and streamlining government...more

Morrison & Foerster LLP

What's Changed in California's Diversity Reporting Law

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On June 29, 2024, California Governor Gavin Newsom signed into law S.B. 164 (the “Diversity Reporting Law”), amending the previous version of the law that was adopted in 2023, S.B. 54. Please visit the following link for our...more

Eversheds Sutherland (US) LLP

AI at the gate: NYDFS issues guidance on addressing new AI-driven cybersecurity risks under existing cybersecurity requirements

On October 16, 2024, the New York State Department of Financial Services (DFS) issued an industry letter providing guidance on how DFS-regulated entities (covered entities) should be evaluating and responding to artificial...more

Paul Hastings LLP

U.S. Government Issues Proposed Rules in Significant Step to Restrict Outbound U.S. Investment in Chinese Technology

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On June 21, 2024, the Treasury Department released long-expected proposed regulations to curtail investments by U.S. persons (including investments by U.S. limited partners in non-U.S. pooled funds) and U.S.-controlled...more

Ward and Smith, P.A.

Navigating the National Practitioner Data Bank: A Guide for Healthcare Professionals (NPDB or Data Bank).

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Few aspects of the healthcare regulatory apparatus evoke more confusion and dread for healthcare practitioners than the National Practitioner Data Bank (NPDB or Data Bank).  Being reported to the Data Bank is often regarded...more

Shipkevich PLLC

CFPB to Begin Tracking Offenders through National Registry

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The CFPB has issued a final rule to provide transparency and track certain covered nonbank offenders. On June 3, 2024, the CFPB introduced a significant regulatory measure known as the Registry of Nonbank Covered Persons...more

Bradley Arant Boult Cummings LLP

Mandatory Cybersecurity Incident Reporting: The Dawn of a New Era for Businesses

A significant shift in cybersecurity compliance is on the horizon, and businesses need to prepare. Starting in 2024, organizations will face new requirements to report cybersecurity incidents and ransomware payments to the...more

Rivkin Radler LLP

[Webinar] Lunch and Learn Series: Conducting HIPAA Breach Assessments and Disclosures: Requirements and Tips for Success - June...

Rivkin Radler LLP on

On Thursday, June 13, the next installment of Rivkin Radler’s Healthcare Compliance Lunch & Learn series, will be presented by Rivkin Radler Partner Ashley Algazi and moderated by Robert Hussar. The program, “Conducting HIPAA...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Amends Reg S-P To Strengthen Data Breach Response Requirements and Protect Investor Information

On May 16, 2024, the Securities and Exchange Commission (SEC) announced the adoption of amendments to Regulation S-P (Reg S-P), which broadly track the changes originally proposed in March 2023. The revised Reg S-P requires...more

Proskauer - Tax Talks

Proposed Regulations Issued on the Excise Tax on Repurchases of Corporate Stock

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On April 9, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) issued two sets of proposed Treasury Regulations related to section 4501, REG-115710-22, which provides guidance on...more

Jones Day

Delegation Dilemma: CFTC Rule Allows Staff to Circumvent Notice and Comment Rulemaking

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The Commodity Futures Trading Commission ("CFTC") published a final rule on April 30, 2024, altering how covered entities fulfill their large trader reporting obligations ("the LTR Rule") and granting CFTC staff significant...more

WilmerHale

8 Questions To Ask Before Final CISA Breach Reporting Rule

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On April 4, the Cybersecurity and Infrastructure Security Agency published a notice of proposed rulemaking setting out mandatory reporting requirements for covered entities that experience cybersecurity incidents or make...more

Bass, Berry & Sims PLC

CISA Publishes Proposed Rule for Cyber Reporting

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On April 4, the U.S. Cybersecurity and Infrastructure Security Agency (CISA) published its much-anticipated Notice of Proposed Rule Making for the Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA)....more

Jones Day

CISA Releases Proposed Cyber Incident and Ransom Payment Reporting Rules to Implement CIRCIA

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CISA's proposed rules will require organizations operating in U.S. critical infrastructure sectors to report cyber incidents within 72 hours and ransom payments within 24 hours. ...more

Pillsbury Winthrop Shaw Pittman LLP

New CISA Rule Would Require Widespread Cyber Incident Reporting, Updated Timelines and Penalties for Critical Infrastructure...

Most businesses in the United States will have to file incident reports—including for ransomware payments—under the Proposed Rule. The Department of Homeland Security has the authority to issue subpoenas and even penalties...more

Schwabe, Williamson & Wyatt PC

Comments Sought on Proposed Requirements of the Cyber Incident Reporting for Critical ‎Infrastructure Act

On March 15, 2022, the Cyber Incident Reporting for Critical Infrastructure Act of 2022 was signed into law. Generally, CIRCIA requires “covered entities,” defined as entities in certain critical infrastructure sectors, to...more

Venable LLP

CIRCIA: Cyber Incident Reporting for Practically Everyone?

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A sweeping array of businesses are another step closer to requirements to report cybersecurity incidents and ransomware payments to the federal government. On April 4, 2024, the U.S. Department of Homeland Security's (DHS)...more

A&O Shearman

Integrating Sustainability: Luxembourg's Legal Advancements with the CSRD

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On the 2nd of April, a pivotal legislative proposal, bill of law number 8370, was introduced in the Luxembourg Parliament to transpose the Corporate Sustainability Reporting Directive (CSRD) into national law. The CSRD will...more

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