News & Analysis as of

Data Breach Form 10-K Securities and Exchange Commission (SEC)

Morrison & Foerster LLP

SEC Caps 2024 with Another Cyber Enforcement Action

The SEC continues to leave its mark as a federal cybersecurity enforcer and closed out the year by charging another company with making misleading statements about a cybersecurity attack and failing to maintain cyber-related...more

Jackson Lewis P.C.

Data Protection Update: Q4 Noteworthy Dates

Jackson Lewis P.C. on

Cross Border Transfers of Data. UK Data Transfers. The UK government has published a U.S. “adequacy decision” which permits U.S. organizations that have certified to the EU-US Data Privacy Framework (DPF) and UK Extension...more

Carlton Fields

SEC Deals New Cybersecurity Disclosure Requirements to Public Companies

Carlton Fields on

On July 26, 2023, the SEC adopted new cybersecurity rules, which have two top-line impacts. First, registrants must disclose material cybersecurity incidents promptly on Form 8-K. Second, registrants must disclose new...more

Epstein Becker & Green

SEC Finalizes Cybersecurity Rule: What It Means

Epstein Becker & Green on

On July 26, 2023, the Securities and Exchange Commission (“SEC”) adopted its long-anticipated cybersecurity reporting rule (the “Final Rule”). The Final Rule applies to public companies subject to the reporting requirements...more

Robinson+Cole Data Privacy + Security Insider

SEC Adopts New Cybersecurity Rules for Public Companies

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

Cadwalader, Wickersham & Taft LLP

SEC Disclosure Requirements for Material Cybersecurity Incidents Updated

The Securities and Exchange Commission (“SEC”) has admonished companies to report material cybersecurity incidents in their public filings since 2011, but this week the SEC announced a new rule actually requiring disclosure...more

Jones Day

SEC Proposes Amendments Regarding Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure

Jones Day on

As part of the SEC's broader rulemaking initiative, on March 9, 2022, the SEC proposed amendments to enhance and standardize disclosures regarding cybersecurity risk management, strategy, governance, and incident reporting by...more

The Volkov Law Group

The SolarWinds Cyber-Attack – The Devastation and Wreckage

The Volkov Law Group on

The SolarWinds cyber-attack was devastating in scope and impact. If any lesson can be learned from this event, the SolarWinds case presents all the pitfalls, enforcement and reputational damage, rolled into one tragic series...more

Proskauer - Corporate Defense and Disputes

SolarWinds Government Data Breach Leads to Securities Action

The massive data breach of the United States Commerce and Treasury Departments that has roiled the federal government has resulted in federal securities litigation. On January 4, 2021, Plaintiff-Shareholder Timothy Bremer...more

Bass, Berry & Sims PLC

SEC Staff Comments on Chegg’s Data Breach Disclosure and Response; A Real Life Example

Bass, Berry & Sims PLC on

One thing I appreciate about the SEC comment letter process is that it gives real life examples to what is often discussed hypothetically. Take, for example, cybersecurity and steps management should take when a data incident...more

A&O Shearman

SEC Issues $35 Million Fine For Alleged Failure To Disclose Data Breach

A&O Shearman on

On April 24, 2018, the United States Securities and Exchange Commission (“SEC”) instituted a settled administrative proceeding against Altaba Inc., f/d/b/a Yahoo! Inc. (“Yahoo!”) for allegedly failing to disclose a...more

WilmerHale

SEC Targets Inadequate Cyberbreach Disclosure in Yahoo! Settlement

WilmerHale on

On April 24, 2018, the Securities and Exchange Commission announced a settled enforcement proceeding against Altaba Inc. (formerly known as Yahoo! Inc.) arising out of data breaches suffered by Yahoo in 2014, 2015 and 2016....more

Jones Day

SEC Releases Guidance on Public Company Cybersecurity Disclosures

Jones Day on

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

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