In the July edition of our Public Company Watch, we cover key issues impacting public companies, including the new Compliance and Disclosure Interpretations related to the cybersecurity disclosure rules and the recent SEC...more
On June 24, the staff of the U.S. Securities and Exchange Commission's (SEC) Division of Corporation Finance (Division of Corporation Finance) released five new Compliance & Disclosure Interpretations (C&DIs) relating to the...more
Erik Gerding, Director, SEC Division of Corporation Finance, issued a statement to clear up misconceptions following filing of an 8-K disclosing a cybersecurity incident....more
Recently, many of our clients have received similar requests from the staff of the SEC's Division of Enforcement related to the December 2020 SolarWinds cyberattack. We confirmed with the SEC staff that the request is...more
Cybersecurity has played an important role in the U.S. Securities and Exchange Commission’s regulatory agenda during the past year. And it’s likely to become even more important in 2019....more
This newsletter discusses noteworthy updates, key regulatory decisions and upcoming compliance reminders. You are welcome to contact us to discuss any of the topics....more
The Securities and Exchange Commission (the “SEC”) announced Tuesday that Altaba, the entity formerly known as Yahoo! Inc., has agreed to pay a $35 million penalty to settle charges that it misled investors by failing to...more
On February 21, the Securities and Exchange Commission (SEC) published interpretive guidance to assist public companies in preparing disclosures about cybersecurity risks and incidents....more
Much has been written about the SEC’s interpretive guidance on cybersecurity disclosures, issued in late February, including Commissioner Stein’s statement that it under-delivers for investors, public companies, and the...more
In February, the SEC announced that it had adopted long-awaited new guidance on cybersecurity disclosure. While the new guidance builds on Corp Fin's 2011 guidance on this topic, it carries more weight because it bears the...more
On February 21, 2018, the Securities and Exchange Commission (SEC) published a release entitled “Commission Statement and Guidance on Public Company Cybersecurity Disclosures” (“Release”). Designed to assist public companies...more
On February 21, 2018, the Securities and Exchange Commission (SEC) issued an interpretive Commission Statement and Guidance on Public Company Cybersecurity Disclosures (the "Guidance") to assist public companies in meeting...more
Prompted by concern over the increase in the risks and frequency of data breach incidents and other cyber-attacks affecting public companies, the Securities and Exchange Commission recently published interpretive guidance to...more
On February 21, 2018, the Securities and Exchange Commission (SEC) published interpretive guidance, titled “Commission Statement and Guidance on Public Company Cybersecurity Disclosures”(Release No. 33-10459), to assist...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 Securities and Exchange Commission (“SEC”) voted unanimously to approve a statement and interpretive guidance to assist the public in preparing disclosures about cybersecurity risks and incidents on February 21, 2018. The...more
“Cybersecurity risks pose grave threats to investors, our capital markets, and our country.” That sober reminder appears at the beginning of the Securities and Exchange Commission’s February 21, 2018, Commission Statement and...more
On Feb. 20, 2018, the Securities and Exchange Commission approved the issuance of a statement and interpretive guidance related to cybersecurity — the first such statement by the SEC in almost seven years. SEC Chairman Jay...more
On February 21, 2018, the Securities and Exchange Commission released new interpretive guidance on public company disclosures regarding cybersecurity risks and incidents....more
On February 21, 2018, the Securities and Exchange Commission (SEC) approved an interpretive release updating guidance on public company disclosure and other obligations concerning cybersecurity matters. The interpretive...more
This week, the U.S. Securities and Exchange Commission (SEC) issued its first formal interpretative release on public company disclosure obligations relating to cybersecurity since the SEC Division of Corporation Finance’s...more
On February 21, 2018, the U.S. Securities and Exchange Commission (SEC) issued an interpretive release providing guidance for public companies relating to disclosures of cybersecurity risks and incidents. Although the...more
• The U.S. Securities and Exchange Commission (SEC) released, on Feb. 21, 2018, updated guidance regarding public company cybersecurity disclosures. The guidance updates the Commission's 2011 non-binding guidance and...more
The SEC posted today, February 21, 2018 an interpretive release regarding its latest guidance public companies’ disclosure obligations under existing law with respect to matters involving cybersecurity risk and incidents. It...more
Recently the New England Chapter of the National Association of Corporate Directors presented a distinguished panel of current and former securities regulators discussing enforcement and governance issues facing boards of...more