News & Analysis as of

Data Breach Non-Public Information

Husch Blackwell LLP

Federal Trade Commission Amends GLBA’s Safeguards Rule

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Key Point: The Federal Trade Commission (FTC) has amended the Safeguards Rule to require non-banking financial institutions to inform the FTC within 30 days of discovering any unauthorized acquisition of unencrypted customer...more

Oberheiden P.C.

5 Keys to Performing A GLBA Audit

Oberheiden P.C. on

Purpose and Background of the GLBA - The Gramm-Leach-Bliley Act (“GLBA”), also known as the Financial Services Modernization Act of 1999, is a federal statute enacted by Congress in 1999 that requires financial...more

The Volkov Law Group

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

The Volkov Law Group on

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

Goodwin

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

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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

Hinshaw & Culbertson - Privacy, Cyber & AI...

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

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

Mintz - Consumer Product Safety Viewpoints

CPSC Inspector General Concludes 2019 Data Breach Was Much More Significant Than Reported and Caused by Mismanagement and...

On September 25th, the CPSC Office of Inspector General (“OIG”) released its long-awaited report summarizing its investigation of the 2019 CPSC data breach. Most notably, the report finds that the data breach was larger and...more

Sheppard Mullin Richter & Hampton LLP

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

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

Mintz - Privacy & Cybersecurity Viewpoints

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

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

Bracewell LLP

DOJ Announces More Equifax Charges – Credits Chinese Hackers

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On February 10, 2020, Attorney General William Barr announced the indictment of four members of the Chinese military on charges of hacking into Equifax’s computer networks, maintaining unauthorized access to those networks...more

Robins Kaplan LLP

Financial Daily Dose 1.8.2020 | Top Story: Speaker Company Sonos Sues Google for Patent Infringement

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Home speaker maker Sonos has sued Google, accusing the company of “infringing on five of its patents, including technology that lets wireless speakers connect and synchronize with one another.” Sonos had originally partnered...more

BCLP

CPSC Notifies Consumer Product Manufacturers of Possible Data Breach of Safety Information

BCLP on

A number of retailers and manufacturers have recently received notices from the U.S. Consumer Product Safety Commission concerning a possible data breach. The CPSC’s letter advises recipients of an unauthorized release of...more

Moore & Van Allen PLLC

SEC Issues Disclosure Guidance as Part of Continued Focus on Cybersecurity

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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

Sheppard Mullin Richter & Hampton LLP

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

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

Hogan Lovells

SEC Issues New Interpretive Guidance on Cybersecurity Disclosures

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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

Orrick, Herrington & Sutcliffe LLP

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

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

Orrick, Herrington & Sutcliffe LLP

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

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

Hogan Lovells

SEC Issues New Interpretive Guidance on Cybersecurity Disclosures

Hogan Lovells on

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

Akin Gump Strauss Hauer & Feld LLP

Revised SEC Guidance Concerning Disclosure of Cybersecurity Risks and Cyber Incidents

• 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

Jones Day

SEC Releases Guidance on Public Company Cybersecurity Disclosures

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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

Robinson+Cole Data Privacy + Security Insider

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

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

Ballard Spahr LLP

SEC Releases Guidance on Public Company Cybersecurity Disclosures

Ballard Spahr LLP on

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

Burr & Forman

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

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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

Bracewell LLP

Cyberattacked: The SEC Joins the Club

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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

Cadwalader, Wickersham & Taft LLP

Equifax Data Breach Highlights SEC Disclosure Obligations for Public Companies in the Wake of Cybersecurity Attacks

On September 7, 2017, Equifax, one of the country’s three primary credit reporting bureaus, announced it had suffered a major cybersecurity breach that could potentially affect half of the U.S. population. According to the...more

Robinson+Cole Data Privacy + Security Insider

Three Chinese Citizens Charged with Hacking New York Law Firms

Preet Bharara, the U.S. Attorney for the Southern District of New York announced that three Chinese citizens have been charged for attempting to hack into seven law firms that were involved in mergers and acquisitions, in...more

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