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Data Protection Risk Management Disclosure Requirements

Vedder Price

FINRA Publishes 2025 Regulatory Oversight Report

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On January 28, 2025, FINRA published its annual regulatory oversight report for 2025 (Report), which highlights observations and findings from FINRA’s oversight programs. The Report covers 24 topics, and for each topic it...more

Vinson & Elkins LLP

Watch What You Say: SEC Enforcement Scrutinizes Cybersecurity Incident Disclosures

Vinson & Elkins LLP on

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

Baker Botts L.L.P.

AI Legal Watch - January 2025

Baker Botts L.L.P. on

Glass Lewis, one of the leading proxy advisory firms, recently updated its policy guidelines for 2025 to include recommendations regarding board oversight of AI. In the new guidelines, Glass Lewis emphasizes the importance of...more

Constangy, Brooks, Smith & Prophete, LLP

Data Privacy Day Checklist: Top 10 ways to protect your organization's data

Tomorrow is International Data Privacy Day, so a happy day to all! More seriously, data privacy concerns and legislation continue to rapidly increase. It has been estimated that by the end of 2024 more than 75 percent of...more

Spilman Thomas & Battle, PLLC

Decoded Technology Law Insights, V 6, Issue 1, January 2025

Welcome to our sixth volume and first issue of 2025 of Decoded - our technology law insights e-newsletter. We have been publishing for six years and could not continue without our committed readers and your insights....more

Troutman Pepper Locke

Cyber Incident Response Checklist for SEC Compliance

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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

Jones Day

SEC v. SolarWinds: Court Rejects SEC Authority Over Cybersecurity Controls and Most Alleged Disclosure Violations

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The U.S. District Court for the Southern District of New York dismissed the majority of claims that the Security and Exchange Commission ("SEC") asserted against SolarWinds, including claims that the company's alleged...more

Troutman Pepper Locke

SEC Issues Additional Guidance Regarding Cybersecurity Incident Disclosure

Troutman Pepper Locke on

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

Holland & Knight LLP

SEC Cyber Enforcement Update: Which Way Are the SolarWinds Blowing?

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The SEC has been aggressively pursuing cybersecurity investigations and enforcement actions against public companies and foreign private issuers. In these actions, the SEC often alleges one of two theories: 1) that the...more

Skadden, Arps, Slate, Meagher & Flom LLP

Hot Topics: AI and ESG

The US Government Is Using AI To Detect Potential Wrongdoing, and Companies Should Too With agencies such as the SEC and DOJ using AI and other data analytics tools extensively to detect wrongdoing, companies need to adopt...more

Skadden, Arps, Slate, Meagher & Flom LLP

FBI, DOJ and SEC Publish Guidance on Requesting Delayed Reporting of Material Cyber Incidents on Form 8-K: Takeaways for CISOs and...

The U.S. Securities and Exchange Commission (SEC) adopted final rules in 2023 that are intended to enhance and standardize disclosures regarding cybersecurity risk management, strategy, governance and incident reporting by...more

Jones Day

The Climate Report: Fourth Quarter 2023

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REGULATORY ISSUES & UPDATES - Mandatory Climate Change Reporting Requirements Under the New European ESRS E1 - The implementation of the European Sustainability Reporting Standards poses risks for reporting companies,...more

Health Care Compliance Association (HCCA)

11 Years After First Disclosure, L.A. Care Pays $1.3M, Says ‘Processing Errors’ Caused Breaches

Report on Patient Privacy 23, no. 10 (October, 2023) By 2016, it should have been clear to HIPAA covered entities that a security risk analysis—and corresponding risk management plan—were compliance basics. Yet, a new...more

Stikeman Elliott LLP

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

Stikeman Elliott LLP on

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

Nelson Mullins Riley & Scarborough LLP

SEC Adopts New Cybersecurity Disclosure Requirements

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

McDermott Will & Emery

For the General Counsel’s Desk: Managing Enforcement Risks Involving Cookies, Pixels, and Other Tracking Technologies

McDermott Will & Emery on

Data governance is a mission-critical issue for every company and institution in the United States. GCs face a host of pressing cybersecurity concerns. Triaging them requires time, attention, and a well-rounded strategy...more

Ballard Spahr LLP

SEC Adopts New Cybersecurity Reporting Rules, Setting Up Various Compliance Challenges

Ballard Spahr LLP on

After an extensive comment period, the SEC announced on July 26 that it was formally adopting new rules for public companies governing cybersecurity disclosures. The rules had generated significant backlash from public...more

Polsinelli

SEC Adopts Cybersecurity Incident and Risk Management Disclosure Rules

Polsinelli on

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

Thomas Fox - Compliance Evangelist

SEC Formalizes New Rules on Cyber Breach Disclosures

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

Orrick, Herrington & Sutcliffe LLP

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

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

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

Constangy, Brooks, Smith & Prophete, LLP

SEC adopts new rule on cybersecurity risk management, disclosure

On July 26, the Securities and Exchange Commission adopted a new rule regarding cybersecurity risk management, strategy, governance, and incident disclosure. The “Cybersecurity Incident Disclosure Rule” will be applicable to...more

Bilzin Sumberg

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

Bilzin Sumberg on

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

Stinson - Corporate & Securities Law Blog

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

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

Jenner & Block

Client Alert: SEC’s Approach to Enforcement After Cyber Incidents: Key Takeaways for Public Companies from a Recent Speech

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Last month, Gurbir Grewal, the Director of the SEC’s Division of Enforcement, spoke at the Financial Times Cyber Resilience Summit. During the remarks, he outlined the importance of cybersecurity and signaled that the SEC is...more

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