News & Analysis as of May 8, 2025

Securities Regulation

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Follow this channel for advisories on one of the biggest threats to businesses today. Read a morning brief of fresh guidance and commentary by leading lawyers on security, privacy, risk management, global regulations, data protection, leaks, hacking, cyber insurance, compliance, HIPAA, and every other aspect of cybersecurity of import to corporate readers right now. less -

2024 Trends in First Circuit Class Actions

Pierce Atwood LLP on 3/27/2025

We are pleased to present our final 2024 update to the New England and First Circuit Class Action Tracker, which focuses on class action filings in state and federal courts within the boundaries of the First Circuit in New...more

Watch What You Say: SEC Enforcement Scrutinizes Cybersecurity Incident Disclosures

Vinson & Elkins LLP on 1/31/2025

On January 13, 2025, the Securities and Exchange Commission (“SEC”) filed a settled enforcement action against Ashford Inc. (“Ashford” or “the Company”), a company that provides products and services to the real estate and...more

Cyber Incident Response Checklist for SEC Compliance

Troutman Pepper Locke on 10/21/2024

By now, public companies are generally aware of the cybersecurity rules adopted by the U.S. Securities and Exchange Commission a year ago, requiring public companies to disclose material cybersecurity incidents under Item...more

SEC Cybersecurity Incidents Disclosures: Materiality, Decryptors, and Ransom Payments - Dear Mary – Incidents + Investigations...

Troutman Pepper Locke on 9/11/2024

I work for a public company that recently experienced a ransomware attack. Fortunately, we were able to restore our business operations quickly by obtaining a decryption key from the threat actor. Given that we managed to get...more

SEC Issues Additional Guidance Regarding Cybersecurity Incident Disclosure

Troutman Pepper Locke on 7/17/2024

On June 24, the staff of the U.S. Securities and Exchange Commission's (SEC) Division of Corporation Finance (Division of Corporation Finance) released five new Compliance & Disclosure Interpretations (C&DIs) relating to the...more

Final Amendments to Regulation S-P under Securities Exchange Act of 1934

Hinckley Allen on 5/28/2024

On May 15, 2024, the Securities and Exchange Commission (the “SEC”) issued final amendments (the “Amendments”) to Regulation S-P (originally adopted in 2000), which governs the treatment of a customer’s nonpublic personal...more

SEC Adopts Amendments to Regulation S-P

Mayer Brown on 5/21/2024

On May 15, 2024, the U.S. Securities and Exchange Commission (“SEC”) adopted amendments (the “Amendments”) to Regulation S-P under the Securities Exchange Act of 1934 (the “Exchange Act”), which governs the treatment of...more

SEC, Solar Winds and Compliance

Thomas Fox - Compliance Evangelist on 11/7/2023

The recent SEC lawsuit against SolarWinds Corp and its CISO, Tim Brown, following the 2020 data breach, has brought the issue of executive liability in cybersecurity disclosures to the forefront. This case sheds light on the...more

SEC Hits SolarWinds and CISO with Investor Fraud Suit Over Cybersecurity

Robinson+Cole Data Privacy + Security Insider on 11/6/2023

In a first, bold move by the Securities and Exchange Commission (SEC) following its new Rules on Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure by Public Companies, issued on July 26, 2023, this...more

SEC Adopts New Cybersecurity Disclosure Rules for U.S. Public Companies and Foreign Private Issuers

Stikeman Elliott LLP on 9/7/2023

The Securities and Exchange Commission (“SEC”) adopted new rules requiring the disclosure of cybersecurity risk management, strategy, governance and material incidents (the “Rules”), effective September 5, 2023. The Rules...more

SEC Adopts New Cybersecurity Disclosure Requirements

Nelson Mullins Riley & Scarborough LLP on 9/6/2023

The Securities and Exchange Commission (“SEC”) adopted the final rules (the “Final Rules”) on July 26, 2023 that will require disclosure of material cybersecurity incidents, cybersecurity risk management, strategy, and...more

SEC Adopts Robust New Cybersecurity Disclosure Rules

The Volkov Law Group on 8/9/2023

In late July 2023, the Securities and Exchange Commission (“SEC”) adopted new rules requiring public companies to disclose cybersecurity incidents and cybersecurity governance policies and practice. The SEC largely adopted...more

SEC Publishes Public Company Cybersecurity Disclosure Final Rule

Seyfarth Shaw LLP on 8/2/2023

What Happened - On July 26, the U.S. Securities & Exchange Commission (SEC) adopted its Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure final rule on a 3-2 vote. The final rule is a modified...more

SEC Mandates New Cybersecurity Disclosures

A&O Shearman on 8/2/2023

On July 26, 2023, the SEC adopted final rules that require public companies to promptly disclose material cybersecurity incidents on Form 8-K and detailed information regarding their cybersecurity risk management and...more

SEC Adopts Cybersecurity Incident and Risk Management Disclosure Rules

Polsinelli on 8/2/2023

On July 26, 2023, the Securities and Exchange Commission (the “SEC”) adopted new rules requiring public companies to disclose within four business days material cybersecurity incidents they experience and to disclose annually...more

SEC Formalizes New Rules on Cyber Breach Disclosures

Thomas Fox - Compliance Evangelist on 8/2/2023

The SEC has recently voted on new rules that will require companies to disclose material cybersecurity incidents within four days and to make disclosures about their broad cybersecurity risks in their annual report. Tom Fox...more

SEC Adopts Cybersecurity Disclosure Rules for Public Companies

Wilson Sonsini Goodrich & Rosati on 8/2/2023

On July 26, 2023, the U.S. Securities and Exchange Commission (SEC) approved final rules requiring that public companies report material cybersecurity incidents as well as disclose their cybersecurity risk management,...more

SEC adopts breach-reporting rules, establishes requirements for cybersecurity risk management

Orrick, Herrington & Sutcliffe LLP on 7/31/2023

On July 26, a divided SEC adopted a final rule outlining disclosure requirements for publicly traded companies in the event of a material cybersecurity incident. ...more

SEC Adopts New Cybersecurity Rules for Public Companies

Robinson+Cole Data Privacy + Security Insider on 7/28/2023

In a 3-2 vote, the Securities and Exchange Commission (SEC) adopted new cybersecurity rules yesterday (July 26, 2023) applicable to public companies. The rules, which will become effective thirty days after publication in...more

SEC’s New Cyber Incident Disclosure Requirements Will Go Into Effect in December

Bilzin Sumberg on 7/27/2023

Come December 2023, public companies will have a very narrow window to report cybersecurity incidents that materially affect their companies. Companies will also have to report annually how they assess and manage...more

SEC Adopts Rules on Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure by Public Companies

Stinson - Corporate & Securities Law Blog on 7/27/2023

The SEC adopted final rules requiring registrants to disclose material cybersecurity incidents they experience and to disclose on an annual basis material information regarding their cybersecurity risk management, strategy,...more

SEC Stirs Its Pot of Cybersecurity Preparedness and Response Proposals

Carlton Fields on 6/14/2023

The SEC remains laser-focused on cybersecurity, with the agency recently reopening the comment period on a sweeping rule for investment advisers and investment companies. In addition, the SEC issued proposed enhancements to...more

SEC Issued Proposed Rule on Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure

Stinson - Government Contracting Matters on 4/22/2022

Increasingly, the Federal government implements a rule for government contractors which then makes its way in some form into all of US industry. Cybersecurity regulations, mandating that government contractors, grant and...more

SEC Proposes Public Company Cybersecurity Disclosure Rules

Stinson LLP on 3/25/2022

On March 9, 2022, the Securities and Exchange Commission (SEC) proposed amendments to its rules that would require certain cybersecurity-related disclosures by public companies. The proposed rules are intended to enhance and...more

SEC Proposes Rules on Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure by Public Companies

Jenner & Block on 3/17/2022

Last week, the SEC proposed rule amendments to enhance and standardize disclosures regarding cybersecurity risk management, strategy, governance, and incident reporting by public companies. The proposed rules include an...more

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