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SEC Moves to Update Transfer Agent Rules; New Rules Likely to Impact Unclaimed Property and Cybersecurity

On December 22, 2015, the Securities and Exchange Commission took the first step in overhauling SEC regulation of transfer agents, the little-discussed but critical intermediaries involved in the prompt clearance and settlement of almost all U.S. securities. After many years in which other types of financial market intermediaries took center stage on the SEC’s rulemaking agenda, the...

NAIC Cybersecurity Forum Focuses on Escalating Threats and Best Remediation Practices

On September 10, the National Association of Insurance Commissioners (NAIC) co-sponsored a cybersecurity forum at the Center for Strategic and International Studies in Washington, DC. Featuring an impressive line-up of senior government officials and knowledgeable experts, the forum aimed to increase understanding of the escalating threat environment, emerging best practices in cyber...

Cybersecurity Is Key Priority for FSOC in 2015

Cybersecurity was a critical area of focus of the Financial Stability Oversight Council’s (“FSOC”) recently released 2015 Annual Report (the “Report”).  The Report, which provides both a consolidated view of important challenges facing the financial system and a road map of FSOC’s key priorities in the upcoming year, identified cybersecurity as a growing concern and warned that cyber...

What Funds Can Take Away From SEC Cybersecurity Guidance

In late April 2015, the U.S. Securities and Exchange Commission responded to the heightened risk of data breaches at the entities it regulates by issuing prescriptive guidance on cybersecurity for all investment advisers and registered investment companies, including mutual funds, insurance separate accounts and business development companies (funds). In her article for Law360,...

President Issues Executive Order Establishing New Sanctions Regime to Combat Cyber Attack Threats

On April 1, 2015, President Obama issued Executive Order 13694, which effectively establishes a new sanctions regime designed to combat cyber-attack threats. Specifically, this Executive Order grants authority to the Secretary of the Treasury, in consultation with the Attorney General and the Secretary of State, to impose sanctions on individuals and entities that are found to be...

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