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
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
• 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
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
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
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
In a case of “cyber meets securities fraud,” the United States Attorney’s Office for the Southern District of New York (“SDNY”) recently indicted three foreign nationals on charges of insider trading, wire fraud, and computer...more
SEC Chicago Regional Director David Glockner spoke at a PLI Conference in New York on June 6 regarding the SEC’s data security regulations and enforcement efforts. Mr. Glockner acknowledged frustration with the Division of...more