News & Analysis as of

Proposed Rules Cybersecurity Disclosure Requirements

Keating Muething & Klekamp PLL

Pay vs. Performance and Cybersecurity Disclosure Rules: Will the SEC Retract Rulemaking?

On March 31, 2025, members of the U.S. House of Representatives Committee on Financial Services sent a letter to Mark Uyeda, Acting Chairman of the U.S. Securities and Exchange Commission. Seeking to “undo the damage from...more

Sheppard Mullin Richter & Hampton LLP

DoD Issues Proposed Rule for New Disclosures on Foreign Review of Computer Code

On November 15, 2024, the Department of Defense (“DoD”) issued a long-awaited Proposed Rule to implement Section 1655 of the National Defense Authorization Act for Fiscal Year 2019. Section 1655 prohibits DoD from...more

Carlton Fields

Going Up: SEC Cyber Incident Reporting - Regulation S-P Amendments Take It to Next Level

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On May 16, 2024, the SEC breathed new life into its decades-old Regulation S-P, which requires firms to adopt policies and procedures for the protection of customer information and records. The amended rule balloons the...more

Skadden, Arps, Slate, Meagher & Flom LLP

Understanding SEC’s Focus Amid Lack of Final AI Rules

Last year, the U.S. Securities and Exchange Commission (SEC) proposed ambitious rules relating to artificial intelligence (AI) that have drawn significant commentary and criticism. While it is unlikely that any changes in the...more

Perkins Coie

Preparing for the 2024 Public Company Reporting Season

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In anticipation of the upcoming reporting season, this Update highlights some of the most significant rule changes, guidance, institutional investor areas of focus, and trends for public companies to consider in preparing...more

ArentFox Schiff

Top 10 ESG Developments for 2023

ArentFox Schiff on

2023 saw terms like “ESG,” “greenwashing,” and “circular economy” come into common use. We also saw a tsunami of other environmental, social, and governance (ESG)-related developments at the international, federal, and state...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - November 2023

...SEC Adopts Amendments to Fund Names Rule - On September 20, 2023, the U.S. Securities and Exchange Commission (SEC) adopted amendments to Rule 35d-1 under the Investment Company Act of 1940 (the Fund Names Rule) as well...more

Jenner & Block

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

Jenner & Block on

On July 25, 2023, the US Securities and Exchange Commission (the SEC), by a 3-2 vote, adopted final rules regarding cybersecurity risk management, strategy, governance and incident reporting by public companies (the Final...more

McDermott Will & Emery

SEC Imposes New Cybersecurity Disclosure Requirements

McDermott Will & Emery on

At an Open Meeting on July 26, 2023, the US Securities and Exchange Commission (SEC) adopted final rules and amendments that impose new cybersecurity-related disclosure requirements for public companies subject to the...more

Shutts & Bowen LLP

SEC Adopts New Cybersecurity Rules

Shutts & Bowen LLP on

In yet another indication of the increasing weight being given by government officials to cybersecurity, on July 26, 2023, the Securities and Exchange Commission adopted new rules requiring public companies to disclose...more

Foley Hoag LLP

SEC Adopts Cyber Regulations

Foley Hoag LLP on

On July 26, 2023, the Securities and Exchange Commission (SEC) adopted rules requiring disclosure of material cybersecurity incidents as well as periodic disclosure of cybersecurity risk, management, strategy, and governance...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Adopts Rules for Cybersecurity Risk Management, Strategy, Governance and Incident Disclosure

On July 26, 2023, the U.S. Securities and Exchange Commission (SEC) voted 3-2 to adopt final rules that are intended to enhance and standardize disclosures regarding cybersecurity risk management, strategy, governance and...more

Sullivan & Worcester

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

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The SEC today adopted 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

BakerHostetler

The SEC's Proposed Cybersecurity Rules: Regulatory Delay Does Not Bless Standing By

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The SEC’s Cybersecurity Proposals - The SEC has proposed four rules designed to address cybersecurity risk and management, including incident reporting by public companies....more

Holland & Knight LLP

Podcast - SEC's Oversight on Cybersecurity Requirements

Holland & Knight LLP on

In this episode of "Counsel That Cares," privacy and cybersecurity attorney Bess Hinson discusses the shifting oversight by the U.S. Securities and Exchange Commission (SEC) on cybersecurity requirements. This digital health...more

Wilson Sonsini Goodrich & Rosati

Preparing for the SEC’s Cybersecurity Disclosure Rules

The U.S. Securities and Exchange Commission’s (SEC) 2023 Spring Unified Agenda of Regulatory and Deregulatory Actions was released last month and includes an anticipated action date for finalizing rules for cybersecurity...more

Seward & Kissel LLP

SEC Updates for the Upcoming 2022 Annual Reports on Form 10-K and Form 20-F

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The U.S. Securities and Exchange Commission (the “SEC”) has adopted amendments and updated disclosure requirements that are to be included in a reporting company’s annual report on Form 10-K or 20-F. The SEC has also proposed...more

Pillsbury Winthrop Shaw Pittman LLP

The SEC’s Fast-Approaching Cybersecurity Overhaul for Public Companies and Regulated Entities

The SEC has nearly doubled the size of its Crypto Assets and Cyber Unit and has aggressively pursued cyber-related enforcement actions against public companies and regulated entities. In a few months the SEC will finalize...more

Davis Wright Tremaine LLP

SEC Looks to Finalize Proposed Cyber Rules, Issue New NPRM

The U.S. Securities and Exchange Commission (SEC) appears to have big plans for cybersecurity regulation in 2023....more

Morrison & Foerster LLP

Private Fund Advisers 2023 Regulatory Outlook

Sponsors and managers of private funds must attend to various routine regulatory and compliance tasks, which can include ongoing reporting obligations under the Investment Advisers Act of 1940 (the “Advisers Act”), updating...more

BakerHostetler

Preparing for the 2023 Proxy and Annual Reporting Season: Key Issues and Considerations

BakerHostetler on

Companies are beginning to look ahead to the upcoming 2023 proxy and annual reporting season, and there are a number of key issues to consider as preparations commence. This alert provides an overview of these issues and...more

Wiley Rein LLP

FTC Launches Rulemaking on Fee Disclosures and Practices Across Industries

Wiley Rein LLP on

On October 20, 2022, the Federal Trade Commission (FTC) announced the launch of a new rulemaking process to address how fees are charged for goods or services, focusing on potentially “deceptive or unfair” fees that the FTC...more

Alston & Bird

SEC Reopening Comments After Technical Issues

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The Securities and Exchange Commission has reopened comments for nearly two dozen proposed rules and other matters. Our Securities Group details the list that includes some controversial rules about cybersecurity, SPACs, and...more

Vinson & Elkins LLP

A Second Chance: The SEC Reopens Comment Periods on Climate, Cyber and Other Rule Proposals in Response to Technical Glitch

Vinson & Elkins LLP on

A technological error in the online comment portal on sec.gov has prevented the Securities and Exchange Commission (“SEC”) from receiving comments on twelve rule proposals (the “Affected Proposals”), according to a new SEC...more

Wilson Sonsini Goodrich & Rosati

SEC Reopens Comment Periods for Certain Rulemaking Releases

On October 7, 2022, the U.S. Securities and Exchange Commission (SEC) announced that it will reopen the public comment periods for 11 rulemaking releases and one request for comment due to a technological error that resulted...more

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