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The SEC’s Cybersecurity Enforcement Action: Rulemaking by Enforcement

The Securities and Exchange Commission recently brought an enforcement action against an investment adviser that, like a large number of companies, was the victim of a cyberattack. Although the SEC did not allege that any of the firm’s clients suffered harm, the Commission nonetheless sanctioned the firm for its allegedly unreasonable policies and procedures. In their article for...

DOJ Publishes Cyberincident Response Best Practices Document

The Cybersecurity Unit of the Department of Justice (DOJ) has published a “best practices” document to assist organizations in developing a response plan for cyberincidents. The document, titled Best Practices for Victim Response and Reporting of Cyber Incidents, focuses on steps organizations should take before, during and after a cyberincident and emphasizes the need for...

CFTC Holds Cybersecurity Roundtable March 18

As noted in our previous entry, staff from the Commodity Futures Trading Commission (CFTC) held a Public Roundtable on Cybersecurity and System Safeguards Testing on March 18, 2015. The Roundtable, which included participants from the private sector and government agencies, could be a kick-off event for a larger CFTC initiative to address issues related to cybersecurity. The Roundtable...

New York’s Insurance Regulator Announces Results of Cybersecurity Survey and Previews New Regulatory Initiatives

On February 9, the New York Department of Financial Services (DFS) released a Report on Cyber Security in the Insurance Sector (Report), summarizing the results of a survey completed by 43 insurers about their cybersecurity programs, costs and future plans. The Report also announced a series of measures that DFS will take in the future to help strengthen cybersecurity in the insurance...

Cybersecurity Announced as a 2015 Exam Priority by the SEC and FINRA

In January 2015, the U.S. Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) each announced their 2015 examination priorities, and both agencies emphasized cybersecurity as a primary exam focus (SEC Examination Priorities, FINRA Examination Priorities). The SEC has designated cybersecurity as a market-wide risk in its examination priorities...

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