News & Analysis as of September 19, 2024

Cybersecurity › Non-Public Information

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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 -

Wisconsin Adopts New Insurance Cybersecurity Law

Hinshaw & Culbertson - Privacy, Cyber & AI... on 8/10/2021

On July 15, 2021, Wisconsin Governor Tony Evers signed Act 73 (Act) into law, making Wisconsin the latest state to adopt the National Association of Insurance Commissioner's (NAIC) model cybersecurity law. Most recently, Iowa...more

First American Financial Corporation Settles SEC Case for $487,616 for Cybersecurity Data Breach and Disclosure Failures

The Volkov Law Group on 6/17/2021

The Securities and Exchange Commission is gaining traction in the enforcement of cybersecurity and disclosure requirements. The SEC has a lot on its plate these days – ESG, cybersecurity, and the traditional mix of...more

7 Steps to Address Privacy Concerns Arising with the Remote “Invisible Workforce”

Fisher Phillips on 4/26/2021

As remote work continues, employers have begun to characterize remote workers as the “invisible workforce” – because remote workers are not able to be seen or monitored in the same way as those performing in-person work. The...more

Maine Enacts NAIC-Inspired Cybersecurity Law

Hinshaw & Culbertson - Privacy, Cyber & AI... on 4/9/2021

Maine has become the latest state to adopt a version of the National Association of Insurance Commissioners (NAIC) model cybersecurity law. Signed into law on March 17, 2021, the Maine Insurance Data Security Act establishes...more

NYDFS Consent Order Signals Regulator’s Growing Focus On Financial Institutions’ Incident Response And Security Practices

Goodwin on 3/23/2021

In early March, the New York State Department of Financial Services (“NYDFS”) announced a consent order that required Maine-based mortgage servicer Residential Mortgage Services, Inc. (“Residential”) to pay a $1.5 million...more

New York State Department of Financial Services Warns of New Fraudulent Campaign Targeting Consumer NPI

Hinshaw & Culbertson - Privacy, Cyber & AI... on 2/26/2021

On February 16, the New York State Department of Financial Services (DFS) issued a cyber fraud alert, warning of a growing cybercriminal campaign to steal consumer, Nonpublic Information (NPI). The hacked data is being taken...more

What the First Enforcement Action under NYDFS Cybersecurity Reg Means to Companies

Sheppard Mullin Richter & Hampton LLP on 9/24/2020

Late this summer the New York Department of Financial Services (NYDFS) announced its first enforcement action since the cybersecurity rules went into effect in March 2017. The action was brought against First American Title...more

NYDFS’ First Cybersecurity Enforcement Action - What Happened and Important Lessons for Organizations

Mintz - Privacy & Cybersecurity Viewpoints on 8/12/2020

The New York State Department of Financial Services (“NYDFS”) has announced its first enforcement action of NYDFS’ Cybersecurity Regulation, Part 500 of Title 23 (“Cybersecurity Regulation”) against First American Title...more

SEC Issues Disclosure Guidance as Part of Continued Focus on Cybersecurity

Moore & Van Allen PLLC on 9/18/2018

As cybersecurity attacks have continued to gain prominence as a threat posing critical risk management and compliance challenges for financial institutions, the Securities and Exchange Commission (SEC) has emerged as an...more

NYS DFS September 4, 2018 Cybersecurity Compliance Deadline

Moore & Van Allen PLLC on 9/7/2018

Tuesday, September 4, 2018 marked the New York State Department for Financial Service’s deadline for compliance with several sections of cybersecurity regulation 23 NYCRR 500 (the “Regulation”). The Regulation covers any...more

You Might Be an Inside Trader If…You Trade on Your Unconfirmed Suspicions of a Cybersecurity Event Prior to Its Public Revelation...

Sheppard Mullin Richter & Hampton LLP on 6/27/2018

Earlier this year, the SEC released cybersecurity guidance addressing, among other things, the risk of insider trading in the event of a data breach. This risk comes in multiple forms, including the intruders trading on...more

SEC Issues Cybersecurity Disclosure Guidance

Carlton Fields on 4/12/2018

On February 21, the SEC published interpretive "Guidance" to help public operating companies prepare disclosures about cybersecurity risks and incidents. ...more

SEC Issues New Interpretive Guidance on Cybersecurity Disclosures

Hogan Lovells on 3/22/2018

On February 21, the Securities and Exchange Commission (SEC) published interpretive guidance to assist public companies in preparing disclosures about cybersecurity risks and incidents....more

SEC Commissioners Provide Guidance On Cybersecurity Disclosures After Wave Of Record Incidents

Orrick, Herrington & Sutcliffe LLP on 3/16/2018

Much has been written about the SEC’s interpretive guidance on cybersecurity disclosures, issued in late February, including Commissioner Stein’s statement that it under-delivers for investors, public companies, and the...more

SEC Commissioners Provide Guidance on Cybersecurity Disclosures After Wave of Record Incidents

Orrick, Herrington & Sutcliffe LLP on 3/14/2018

The Commission's "new" cybersecurity guidance largely rehashes existing guidance, as is highlighted by objections from two commissioners. At most, the additional qualitative guidance is incremental. It reiterates the need to...more

SEC Issues New Interpretive Guidance on Cybersecurity Disclosures

Hogan Lovells on 3/6/2018

Prompted by concern over the increase in the risks and frequency of data breach incidents and other cyber-attacks affecting public companies, the Securities and Exchange Commission recently published interpretive guidance to...more

Revised SEC Guidance Concerning Disclosure of Cybersecurity Risks and Cyber Incidents

Akin Gump Strauss Hauer & Feld LLP on 3/1/2018

• Disclosures must inform investors about material cybersecurity risks and incidents, including addressing material cybersecurity risks for cyber-attacks that have not yet occurred. • Comprehensive policies and procedures...more

SEC Releases Guidance on Public Company Cybersecurity Disclosures

Jones Day on 2/27/2018

The SEC's new guidance on public company cybersecurity disclosures and Chairman Clayton's accompanying statement emphasize the SEC's expectations that public companies: (i) implement comprehensive cybersecurity policies that...more

SEC Updates Guidance on Public Companies’ Disclosure of Cyber-Attacks

Robinson+Cole Data Privacy + Security Insider on 2/23/2018

The U.S. Securities and Exchange Commission (SEC) updated guidance to public companies this week on how and when they are to disclose cybersecurity risks and breaches. The SEC suggests that public companies should disclose...more

SEC Releases Guidance on Public Company Cybersecurity Disclosures

Ballard Spahr LLP on 2/23/2018

On February 21, 2018, the U.S. Securities and Exchange Commission approved the release of Interpretive Guidance relating to public company disclosures of cybersecurity risks and incidents. ...more

SEC Enforcement Division Priorities Pertaining to Retail Investors and Cybersecurity

Dechert LLP on 11/10/2017

In a keynote speech to the Securities Enforcement Forum on October 26, 2017, U.S. SEC Division of Enforcement (Division) Co-Director Stephanie Avakian emphasized the protection of retail investors and cybersecurity as...more

National Association of Insurance Commissioners Issues Insurance Data Security Model Law

Akin Gump Strauss Hauer & Feld LLP on 11/1/2017

• NAIC recently adopted an Insurance Data Security Model Law that follows the risk assessment-based approach of the New York DFS Cybersecurity Regulation. This signals the growing influence of the New York Regulation,...more

SEC’s Chairman Makes Changes After the Agency’s Latest Cyber-Attack

Burr & Forman on 10/13/2017

The Securities Exchange Commission (“SEC”) has been busy the last couple months on the cyber front. On September 20, the SEC announced a renewed focus on cybersecurity efforts and disclosed that it had been a victim of a...more

Cyberattacked: The SEC Joins the Club

Bracewell LLP on 9/26/2017

On September 20, the Securities and Exchange Commission announced that its system for electronic filing for public company disclosures, EDGAR, was compromised last year and that hackers may have used exposed information for...more

Law Firm Data Breaches Demonstrate the Expanding Scope of Cyber Attacks

Cadwalader, Wickersham & Taft LLP on 1/17/2017

In a case of “cyber meets securities fraud,” the United States Attorney’s Office for the Southern District of New York (“SDNY”) recently indicted three foreign nationals on charges of insider trading, wire fraud, and computer...more

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Cybersecurity › Non-Public Information

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