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SEC Withdraws Proposed Cyber-Related Rule Applicable to Broker-Dealers And Signals SolarWinds Settlement on the Horizon

The Securities and Exchange Commission (SEC) recently announced the withdrawal of several Biden-era regulations, including a proposed rule that would have required a broad range of platforms and financial intermediaries (such...more

Texas AG Files Complaint Against Major Insurance Company Regarding Data Practices

The Texas Office of the Attorney General recently has become increasingly interested in the practices of organizations who collect and utilize consumer data. On January 13, 2025, the Attorney General of Texas, Ken Paxton,...more

NYDFS Releases Consent Order in First Enforcement Action Brought Under the Cybersecurity Regulations

After a three-year investigation/enforcement action by the New York Department of Financial Services (“NYDFS”), NYDFS entered into a Consent Order with a large title insurer (the “Company”) for its violation of NYDFS’s...more

The SEC Sues SolarWinds and Its CISO for Alleged Fraud and Disclosure Controls Failures

Our Securities Litigation, Securities, and Privacy, Cyber & Data Strategy teams outline vital takeaways for public companies and their directors and officers in light of the Securities and Exchange Commission’s recent civil...more

The Latest in the SEC’s Off-Network Communications Enforcement Sweep

On September 29, 2023, the U.S. Securities and Exchange Commission (SEC) announced enforcement actions against five broker-dealers, three dually registered broker-dealers and investment advisers, and two affiliated investment...more

NYDFS Penalizes bitFlyer $1.2 Million for Violations to Cybersecurity Regulation

On May 1, 2023, bitFlyer USA, Inc. (“bitFlyer”) entered into a Consent Order with the New York Department of Financial Services (“DFS”) for multiple deficiencies in bitFlyer’s cybersecurity program, most notably for failure...more

FTC Takes Action Against Ed Tech Provider for Failure to Secure Student’s Personal Information

On October 31, 2022, the Federal Trade Commission (FTC) announced it has taken action against education technology provider Chegg Inc. (“Chegg”) for its “careless” cybersecurity practices that exposed sensitive personal...more

$1.8 Billion in SEC and CFTC Fines Highlights Continued Scrutiny of Unapproved Messaging Platforms

Federal enforcement agencies continue to scrutinize investment advisers’ use of personal devices and messaging platforms to conduct business. Our team reviews how recent penalties should encourage companies to create internal...more

SEC Settles Enforcement Actions with Broker-Dealers and Investment Advisors for Identity Protection Deficiencies

On July 27, 2022, the Securities and Exchange Commission (SEC) separately settled three enforcement actions with broker-dealers and investment advisers for alleged deficiencies relating to the prevention of customer identity...more

SEC Settles Enforcement Action for Disclosure Controls Violations Stemming from Data Security Incident

The SEC has settled an enforcement action against a large title insurer in connection with public statements and disclosures made by the company in May 2019 relating to a data security incident.  The underlying data security...more

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