Debevoise’s Data Strategy and Security group recently assisted four leading trade associations that represent the financial services industry in preparing a joint comment letter in response to the Cybersecurity and…
We have previously written about the legal risks that companies face if they oversell the capabilities of their AI systems, known as “AI washing.” In particular, the FTC and the…
On December 19, 2023, the Federal Trade Commission (the “FTC”) announced a complaint and a proposed stipulated order against a large drugstore chain (the “Company”) in connection with the Company’s…
SIFMA and SIFMA AMG Comment on the SEC’s Proposed Rules for BDs and RIAs Among its many uses in the financial world, technology can improve operational efficiencies, reduce risk and…
The White House has certainly been true to its word on pushing forward on cyber. In July 2023, following the release of the Biden Administration’s (“the Administration”) National Cybersecurity Strategy…
On July 26, 2023, the U.S. Securities and Exchange Commission (“SEC”) issued proposed rules (the “Proposed Rules”) that would require broker-dealers and investment advisers (collectively, “firms”) to evaluate their use…
Last month, we wrote about how many companies probably need a policy for Generative AI tools like ChatGPT, Bard and Claude (which we collectively refer to as “ChatGPT”). We discussed…
On March 2, 2023, the White House Office of the National Cyber Director (“ONCD”) released the Biden Administration’s (the “Administration”) long-awaited National Cybersecurity Strategy (the “Strategy”), the first since the…
In February 2022, the SEC proposed its first-ever cybersecurity rules for registered investment advisers (“RIAs”) (including RIAs to private funds) and Funds (which include registered investment companies (“RICs”) and closed-end…
ChatGPT is an AI language model developed by OpenAI that was released to the public in November 2022 and already has millions of users. While most people were initially using…