Securities and Exchange Commission

On June 15, 2021, the SEC announced it settled charges against real estate services company First American Financial Corporation (“First American”) for alleged violation of Rule 13a-15(a) of the Exchange Act. The SEC charged First American with failure to maintain disclosure controls and procedures designed to ensure that all available, relevant information concerning a software vulnerability that led to a cybersecurity incident was filed with the Commission.

Continue Reading SEC Settles Charges Against Real Estate Services Company Over Control Failures Related to Cybersecurity Disclosure

On January 19, 2021, the UK Information Commissioner’s Office published its analysis of the application of the UK General Data Protection Regulation to transfers from UK-based firms or branches that are registered, required to be registered or otherwise regulated by the U.S. Securities and Exchange Commission.
Continue Reading ICO Confirms UK Firms May Rely on Public Interest Derogation for SEC Transfers

The Securities and Exchange Commission’s Office of Compliance Inspections and Examinations recently announced the publication of a report entitled “Cybersecurity and Resiliency Observations” that summarizes the observations gleaned from OCIE’s cybersecurity examinations of broker-dealers, investment advisers, clearing agencies, national securities exchanges and other SEC registrants.
Continue Reading SEC Publishes Cybersecurity and Resiliency Observations

The Centre for Information Policy Leadership at Hunton Andrews Kurth LLP recently published a white paper on Organizational Accountability’s Existence in U.S. Regulatory Compliance and its Relevance for a Federal Data Privacy Law.
Continue Reading Organizational Accountability in U.S. Law and Its Relevance to a Federal Data Privacy Law: A CIPL Study

On July 9, 2019, the UK Information Commissioner’s Office announced that it intends to fine Marriott International £99,200,396 for a data breach violating the GDPR. This closely follows the £183 million fine for British Airways, announced on July 8.
Continue Reading ICO Announces $124 Million Fine for Marriott International following Data Breach

On September 26, 2018, the SEC announced a settlement with Voya Financial Advisers, Inc., a registered investment advisor and broker-dealer, for violating Regulation S-ID, as well as Regulation S-P. Together, Regulations S-ID and S-P are designed to require covered entities to help protect customers from the risk of identity theft and to safeguard confidential customer information. The settlement represents the first SEC enforcement action brought under Regulation S-ID.
Continue Reading SEC Fines Broker-Dealer $1 Million in First Enforcement Action Under Identity Theft Rule