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Proposed Rules Cybersecurity Policies and Procedures

Foley & Lardner LLP

HHS Proposes Changes to Strengthen HIPAA Security Rule

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Material updates to the HIPAA Security Rule could be on the way — affecting all HIPAA-regulated entities — for the first time in two decades. The Department of Health and Human Services (HHS) issued a Notice of Proposed...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

Miller Canfield

2024 Regulatory Update for Investment Advisers

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In 2023, the Securities and Exchange Commission issued various proposed rules on regulatory changes that will affect SEC-registered investment advisers (RIAs). Since these rules are likely to be put into effect, RIAs should...more

Pillsbury Winthrop Shaw Pittman LLP

Proposed Rules Overhaul Cybersecurity Requirements for Government Contractors

The Federal Acquisition Regulation (FAR) Council has proposed two new cybersecurity rules that would impose significant obligations and risks for federal government contractors. The proposed rules impose substantial cyber...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

Seward & Kissel LLP

FTC Imposes New Data Breach Notification Requirements

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On October 27, 2023, the Federal Trade Commission (the “FTC”) adopted a final rule (“Final Rule”) to amend the Standards for Safeguarding Customer Information (the “Safeguards Rule”). Among other things, the Final Rule will...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

Goodwin

SEC to Impose Significant New Privacy and Cybersecurity Rules for BDs, RIAs, TAs, and Mutual Funds

Goodwin on

The SEC continues its overhaul of cybersecurity, cyber incident reporting, and privacy controls and requirements for industry registrants, their services providers, and corporate America generally. On March 15, 2023, the SEC...more

Vinson & Elkins LLP

SEC Proposes New Cybersecurity Rules for Market Entities

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On March 15, 2023, the Securities Exchange Commission (“SEC”) issued three additional proposed rules that would expand the reach of the agency’s current cybersecurity guidance to new entities and augment existing...more

King & Spalding

SEC Proposes RIA Outsourcing Rule

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On October 26, the SEC proposed a new Advisers Act rule (the “Proposed Rule”) that would establish specific obligations for Registered Investment Advisers with respect to outsourcing of “Covered Functions”, as that term is...more

Paul Hastings LLP

SEC Proposed Cybersecurity Rules – What They Are and What Our Clients Should be Doing Now

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What are the new rules? Earlier this year, the Securities and Exchange Commission (“SEC”) published a new set of proposed cybersecurity disclosure rules for public companies. The proposed rules would significantly increase...more

Moore & Van Allen PLLC

The Devil Really is in the Details: The SEC Proposed Rule on Cybersecurity Risk Management for Investment Advisors, Registered...

Late last month the Securities and Exchange Commission (“SEC”) charged JP Morgan, UBS and Trade Station with violations of Regulation S-ID based on a range of  inadequacies in their identity theft red flag policies and...more

Porter Hedges LLP

Increased Focus on Cybersecurity Warrants Review of Policies and Procedures

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On March 9, 2022, the U.S. Securities and Exchange Commission (“SEC”) proposed amendments to its rules to require additional disclosures regarding cybersecurity risk management, strategy, governance, and incident reporting by...more

Mitratech Holdings, Inc

The Impact of SEC’s Proposed New Rules in Cyber Risk Management

A new discourse in the cyber risk management landscape of US public companies is here. This past March 2022, the US Securities and Exchange Commission (SEC) added another item to their to-do list by announcing a...more

NAVEX

The SEC's Message for Companies on Cybersecurity: ‘Do Better’

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Corporate risk and compliance officers already labor under an influx of concerns related to cybersecurity, so you might have missed this latest news: the U.S. Securities and Exchange Commission has proposed new rules for more...more

Lowenstein Sandler LLP

SEC Proposes New Rules Related to Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure By Public Companies

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Requirements under the proposed rules would include the disclosure of: •Material cybersecurity incidents within four business days of the determination that a material cybersecurity incident has occurred in a Form 8-K- ...more

Ballard Spahr LLP

New SEC Proposed Cyber Rules Signal Concern About Systemic Risk

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After many years of signaling potential expansion of cybersecurity rules, the Securities and Exchange Commission (SEC) has issued in the past month two new sets of proposed rules governing cybersecurity.  The more recent set...more

McGuireWoods LLP

SEC Proposes New, Formal Cybersecurity Disclosure Rules

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On March 9, 2022, the U.S. Securities and Exchange Commission (SEC) proposed a number of new rules to enhance public companies’ reporting of (i) cybersecurity incidents, (ii) their policies and procedures for identifying and...more

Brownstein Hyatt Farber Schreck

SEC Proposes Cybersecurity Disclosure Requirements

On March 9, the Securities and Exchange Commission (SEC) voted to propose cybersecurity disclosure requirements for public companies. The proposal follows the release of interpretive guidance on the matter in both 2011 and...more

BakerHostetler

SEC Proposes Rules on Disclosure of Material Cyber Incidents and Cybersecurity Practices for Public Companies

BakerHostetler on

On March 9, 2022, the SEC released proposed rules intended to enhance and standardize disclosures regarding cybersecurity risk management, strategy, governance and cyber incident reporting by companies that are subject to the...more

Cooley LLP

SEC votes to propose new rules for cybersecurity disclosure and incident reporting [UPDATED]

Cooley LLP on

[This post revises and updates my earlier post primarily to reflect the contents of the proposing release.] - At an open meeting last week, the SEC voted, three to one, to propose regulations “to enhance and standardize...more

Burr & Forman

SEC Proposes Cybersecurity Disclosure Rule For Public Companies

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Continuing its active regulatory agenda, the Securities and Exchange Commission on March 9, 2022, proposed new cybersecurity regulations for reporting public companies. Although couched as a series of “disclosure”...more

K&L Gates LLP

SEC Proposes Cybersecurity Risk Management Rules for Investment Advisers and Funds

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On 9 February 2022, the U.S. Securities and Exchange Commission (the SEC) proposed new rules and amendments to existing rules (together, the Proposed Rules) addressing cybersecurity risk management under the Investment...more

Holland & Knight LLP

SEC Proposes Substantial New Cybersecurity Requirements for Investment Advisers and Companies

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Following U.S. Securities and Exchange Commission (SEC) Chairman Gary Gensler's recent speech directing the agency to expand cybersecurity requirements on regulated entities, the SEC on Feb. 9, 2022, voted to propose new...more

Burr & Forman

SEC Proposes Cybersecurity Rule for Advisers, Investment Companies

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On February 9, the SEC proposed new cybersecurity risk management regulations for investment advisers, registered investment companies (funds), and business development companies....more

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