News & Analysis as of

Securities and Exchange Commission (SEC) Covered Entities

Latham & Watkins LLP

SEC Imposes New Cybersecurity Requirements on Broker-Dealers, Investment Companies, Registered Investment Advisers, and Transfer...

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Covered institutions will need to review their cybersecurity and incident response policies and procedures ahead of the applicable compliance deadline. ...more

Jackson Lewis P.C.

The Broadening Data Security Mandate: SEC Incident Response Plan and Data Breach Notification Requirements

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Virtually all organizations have an obligation to safeguard their personal data against unauthorized access or use, and, in some instances, to notify affected individuals in the event such access or use occurs. Those...more

Dechert LLP

SEC Adopts First Major Amendments to Regulation S-P Since 2000

Dechert LLP on

Incident Response Plans and Written Information Security Programs Continue to be Essential and Will Need to Be Reviewed. Most sophisticated organizations currently have in place incident response plans. Those organizations...more

Stark & Stark

Understanding the Enhanced Regulation S-P Requirements

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On May 16, 2024, the Securities and Exchange Commission adopted amendments to Regulation S-P, the regulation that governs the treatment of nonpublic personal information about consumers by certain financial institutions....more

Epiq

New SEC Cybersecurity Rules: What to Know and How to Remain Compliant

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As addressing cybersecurity issues continues to become a top priority throughout the financial industry, the U.S. Securities and Exchange Commission (SEC) is following suit. The SEC unanimously voted to approve a new set of...more

WilmerHale

SEC Modernizes Data Protection Rules for Safeguarding Customer Information

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Last month, the Securities and Exchange Commission (the SEC or the Commission) unanimously voted to adopt amendments to Regulation S-P (Reg S-P), which is the SEC’s regulation governing the treatment and safeguarding of...more

Dorsey & Whitney LLP

SEC Adopts Amendments to Expand the Requirements of Regulation S-P for Registered Investment Advisers and Broker-Dealers

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On May 16, 2024, the SEC adopted amendments (the “Amendments”) to Regulation S-P to require SEC-registered investment advisers and broker-dealers (collectively, “Covered Institutions”) to develop, implement, and maintain...more

Seward & Kissel LLP

SEC Adopts Data Privacy Rule Amendments to Regulation S-P

Seward & Kissel LLP on

Who may be interested: Investment Companies; Investment Advisers; Broker-Dealers; Transfer Agents - The SEC adopted amendments to Regulation S-P imposing new data privacy and security requirements on broker-dealers,...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Amends Reg S-P To Strengthen Data Breach Response Requirements and Protect Investor Information

On May 16, 2024, the Securities and Exchange Commission (SEC) announced the adoption of amendments to Regulation S-P (Reg S-P), which broadly track the changes originally proposed in March 2023. The revised Reg S-P requires...more

Vinson & Elkins LLP

Cyber(in)security: New York Levies Fine for Failure to Implement Written Policies

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On November 27, 2023, the New York State Department of Financial Services (“DFS”) and First American Title Insurance Company (“First American”) entered into a consent order1 that resolved litigation over First American’s...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

Holland & Knight LLP

Changing of the Guard? SEC Proposes Significant Amendments to the Safeguards Rule

Holland & Knight LLP on

The SEC continued its recent onslaught of proposed cybersecurity rules in mid-March with three new proposals covering a litany of entities, including investment advisers, broker-dealers, investment companies, clearing...more

Sullivan & Worcester

SEC’s Proposed Changes to Regulation S-P Would Overhaul Records and Information Requirements of Covered Institutions

Sullivan & Worcester on

On March 15, 2023, the United States Securities and Exchange Commission (“SEC”) proposed amendments to Regulation S-P that, if finalized, would place additional burdens on covered institutions when it comes to handling...more

Sheppard Mullin Richter & Hampton LLP

Key Corporate Tax Aspects of the New Inflation Reduction Act

On August 16, 2022, President Biden signed into law the Inflation Reduction Act of 2022 (the Act), a sweeping bill with significant tax, energy and healthcare implications...more

Wiley Rein LLP

New York State Department of Financial Services Proposes Updates to Cybersecurity Regulation

Wiley Rein LLP on

On July 29, 2022, the New York Department of Financial Services (DFS) released Draft Amendments to its Part 500 Cybersecurity Rules. These changes are open for a preliminary public comment until August 18, and then an...more

Perkins Coie

Answers to Common Questions Regarding New CIRCIA

Perkins Coie on

President Biden signed into law the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA) on March 15, 2022. The enactment of CIRCIA follows attacks on critical infrastructure, such as the May 2021...more

BCLP

SEC’s Gensler: Major Cybersecurity Regulatory Changes On the Horizon

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A significant expansion of rules relating to cybersecurity risks - particularly for the financial sector - is under consideration by the Securities and Exchange Commission (SEC). In public remarks last week, SEC Chair...more

Pillsbury Winthrop Shaw Pittman LLP

Despite COVID-19 Challenges, No Extension of Form CRS Compliance Date for Investment Advisers

On April 7, 2020, the staff of the Office of Compliance Inspections and Examinations (OCIE) issued a risk alert (Alert) informing investment advisory firms of the potential areas of focus for Form CRS-related examinations. In...more

Pillsbury Winthrop Shaw Pittman LLP

Text, Alexa, Bitcoin—Technology Makes Political Contributions Easier

Is your political compliance program ready for the 2020 election season? With the 2020 election season underway, now is a good time to make certain your internal policies and procedures address applicable campaign...more

Manatt, Phelps & Phillips, LLP

New Guidance From SEC, New York’s DFS

Hoping to help covered entities, the Securities and Exchange Commission (SEC) released an update on cybersecurity while New York’s Department of Financial Services (DFS) published guidance for licensed virtual currency...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

Financial Industry Developments - New York Department of Financial Services Promulgates First-in-the-Nation State Cybersecurity Regulation - On February 16, 2017, the New York Department of Financial Institutions...more

Stinson LLP

Emerging Trends Newsletter - Q3

Stinson LLP on

We are thrilled to bring you the third installment of Stinson Leonard Street's Emerging Trends newsletter. We are proud of the depth and breadth of experience and knowledge across our firm's 13 offices nationwide and are...more

Bilzin Sumberg

Alphabet Soup and Data Security

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In the span of two days, mobile device users learned of two data breaches that could compromise their personal data. In one, Experian (a credit reporting agency) reported that it was hacked, potentially putting 15 million...more

Manatt, Phelps & Phillips, LLP

SEC Ramps up Cybersecurity Scrutiny With Examination Priorities and an Enforcement Action

Why it matters - Signaling that it will continue to increase its scrutiny of firms' cybersecurity readiness, the Office of Compliance, Inspections and Examinations of the Securities and Exchange Commission (SEC) issued a...more

Akin Gump Strauss Hauer & Feld LLP

SEC Adopts Final Pay Ratio Rules

On August 5, 2015, the Securities and Exchange Commission (SEC) voted 3-2 to approve its controversial pay ratio rules. The rules were adopted pursuant to the mandate of Section 953(b)(1) of the Dodd-Frank Wall Street Reform...more

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