On September 20, 2022, the SEC announced settled charges and the imposition of a $35 million penalty against a dually registered investment adviser and broker-dealer (the “Firm”) for violations of Regulation…
On July 29, 2022, the New York Department of Financial Services (“NYDFS”) released Draft Amendments to its Part 500 Cybersecurity Rules. We provided our initial thoughts on the Draft Amendments…
On July 27, 2022, the Securities and Exchange Commission (“SEC”) separately charged three financial institutions with violations of Rule 201 of Regulation S-ID (“Reg S-ID”), also known as the Identity…
On Friday, August 5, 2022, Eric Dinallo, Luke Dembosky, Avi Gesser, Erez Liebermann, and Charu Chandrasekhar participated in a webcast on the proposed draft amendments to the NYDFS cyber rules.…
On July 29, 2022, the New York Department of Financial Services (“NYDFS”) released Draft Amendments to its Part 500 Cybersecurity Rules, which include a mandatory 24-hour notification for cyber ransom…
On April 26, 2022, the Division of Examinations (“EXAMS”) of the Securities and Exchange Commission (the “SEC”) issued a Risk Alert titled “Investment Adviser MNPI Compliance Issues” (“Risk Alert”) on…
On April 19, 2022, Kristin Snyder and Charu Chandrasekhar of Debevoise’s White Collar & Regulatory Defense Group, and Avi Gesser and HJ Brehmer of Debevoise’s Data Strategy & Security Group…
On March 9, 2022, the SEC released its newest series of proposed cybersecurity rules, this time for all public companies. Consistent with the proposed rules issued last month for investment…
On February 9, 2022, the SEC released its much-anticipated proposed rules relating to cybersecurity risk management, incident reporting, and disclosure for investment advisers and funds. Many of the proposals follow…
On January 24, 2022, SEC Chair Gary Gensler gave a speech on cybersecurity rulemaking to the Annual Securities Regulation Institute, outlining a number of key points he expects the SEC…