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SEC Seeks Comment on Cybersecurity Issues in ANPR for Transfer Agents

On December 22, the Securities and Exchange Commission (SEC) issued an advanced notice of proposed rulemaking (ANPR) for new transfer agent requirements, and it also issued a concept release for which public comment on the SEC’s broader review of transfer agent regulation is sought.  In the ANPR, the SEC specifically cited cybersecurity as an area in which the Commission intends to...

Cyber Bill passed into law as part of Omnibus Spending Package

The Cybersecurity Act of 2015 (“Act”), which was added to the fiscal 2016 appropriations measure, was signed into law on December 18, 2015. The Act includes, among other things, incentives for companies to participate in sharing information about data threats with the government and among themselves. Among these incentives is liability protection for those who participate in the...

The Six Lawsuits All GCs Face After a Data Breach

There are many types of litigation likely to arise following a data breach. For more information on the different types of actions that could be initiated by consumers, financial institutions, insurers, shareholders, employees and government agencies after a cyberattack, view this Law360 article.

NIST RFI on Cybersecurity Framework

The National Institute of Standards and Technology (NIST) is seeking information on how it might update and improve its February 2014 ‘‘Framework for Improving Critical Infrastructure Cybersecurity.” The Framework consists of voluntary standards, guidelines, and practices intended to help organizations manage cybersecurity risks. In a Request for Information (RFI) issued on December...

Don’t be a Turkey: Recipes for a Successful and (Hopefully) Cyberattack-Free Thanksgiving

Thanksgiving is a time to give thanks for the important things in life: family, friends, health and (hopefully) not being hacked in the past year.  Those firms and compliance officers who followed our Top 10 Cybersecurity Resolutions for 2015 are hopefully in good shape to continue warding off cyberattacks in the coming year. But for those who haven’t taken to heart our suggested...

European Court of Justice Invalidates Safe Harbor Agreement

On October 6th, the European Court of Justice declared the Safe Harbor data-transfer agreement between the United States and the European Union to be invalid. Safe Harbor established a framework for U.S. companies to transfer personal data of European citizens to the U.S. without violating European privacy rules. The Court’s ruling does not order an immediate end to Safe Harbor...

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