On May 21, 2024, Erik Gerding, the director of the Division of Corporation Finance of the Securities and Exchange Commission (SEC), released a statement containing guidance for public companies regarding the disclosure of...more
Balancing cybersecurity incident disclosures has been a challenge for those in the trenches for years. That has not changed, and recent regulatory activity should not alter the challenges breach counsel confront. In short,...more
A flurry of legislative activity over the past year has brought meaningful changes to a variety of privacy and security provisions in state and federal law. At the state level, as in 2022, we have seen a handful of changes to...more
On April 7, 2020, the staff of the Office of Compliance Inspections and Examinations (OCIE) issued a risk alert (Alert) informing investment advisory firms of the potential areas of focus for Form CRS-related examinations. In...more
On December 28, 2016, the New York Department of Financial Services ("DFS") released a revised version of a proposed regulation that would require banks, insurance companies, and other financial services institutions...more
Following a year of high-profile data breaches, the Securities and Exchange Commission (SEC) announced on January 13, 2015 that, for the second consecutive year, its Office of Compliance Inspections and Examinations (OCIE)...more
As part of a series of “sneak peeks” announced in advance of the State of the Union address on Tuesday, January 20th, President Obama made remarks last week before the Federal Trade Commission, the Department of Homeland...more