On October 16, 2018, the Securities and Exchange Commission (SEC) issued a report outlining an investigation conducted by the SEC’s Division of Enforcement related to the internal accounting controls at nine public companies...more
The Securities and Exchange Commission (“SEC”) released expansive interpretive guidance (“2018 Guidance”), posted February 21, 2018, further building upon its far-reaching cybersecurity guidance provided in 2011. Below are...more
The U.S. Securities and Exchange Commission has issued guidance on cybersecurity disclosure. Companies must establish and maintain appropriate disclosure controls and procedures to make accurate and timely disclosures of...more
On August 28, 2015, the National Futures Association (NFA) submitted a proposed interpretative notice (Notice) to the Commodity Futures Trading Commission (CFTC) to require information systems security programs (ISSPs). If...more