Cybersecurity, Policies and Procedures, Financial Services Industry

What the SEC Amendments to Regulation S-P Mean for Your Business

Tonkon Torp LLP on 2/5/2025

On May 16, 2024, the SEC adopted amendments to Regulation S-P requiring broker-dealers, registered investment companies, registered investment advisers, funding portals, and transfer agents (collectively, “covered...more

Countdown to DORA – Four Takeaway Points From Regulators’ December Statements

Skadden, Arps, Slate, Meagher & Flom LLP on 1/6/2025

The EU’s Digital Operational Resilience Act (DORA) becomes binding on 17 January 2025. As the compliance deadline approaches, EU financial regulators (ESAs) have issued a flurry of statements on the act, including: - An...more

Treasury Highlights AI’s Potential and Risks in Financial Services

Sheppard Mullin Richter & Hampton LLP on 1/6/2025

On December 19, the U.S. Department of Treasury released a report summarizing key findings from its 2024 Request for Information (RFI) on the uses, opportunities, and risks of Artificial Intelligence (AI) in financial...more

EU DORA: Are you in scope, and if so, how can you prepare?

King & Spalding on 12/23/2024

The Digital Operational Resilience Act (DORA) establishes a harmonised and comprehensive framework for information and communication technology (ICT) risk management in the financial sector. It is a directly applicable EU...more

Senate AI Working Group Releases Long-Anticipated Roadmap for AI Policy

Akin Gump Strauss Hauer & Feld LLP on 5/17/2024

On May 15, 2024, the Senate AI Working Group—Senate Majority Leader Chuck Schumer (D-NY) and Sens. Mike Rounds (R-SD), Todd Young (R-IN), and Martin Heinrich (D-NM)—issued their long-anticipated Roadmap for Artificial...more

EU Cyber Legislation Puts Emphasis on Board Responsibility

Mayer Brown on 3/8/2024

What is a Management Body? Under both DORA and NIS2, a management body can be a body with managerial and/or supervisory functions. The powers and structure of management bodies vary within the EU Member State, and managerial...more

NYDFS Finalizes Amendments to Cybersecurity Regulations

WilmerHale on 11/29/2023

On November 1, 2023, New York Department of Financial Services (NYDFS or the “Department”) released the finalized revisions (the “Second Amendment”) to 23 NYCRR Part 500 (Part 500) – the most significant modifications to Part...more

New York Raises the Bar Again: Revised Cybersecurity Requirements for Financial Services Companies Finalized

Eversheds Sutherland (US) LLP on 11/15/2023

On November 1, 2023, the New York Department of Financial Services (NY DFS) published its highly anticipated final amendments to its influential cybersecurity requirements for financial services companies (Part 500)....more

Updated Guidance Notes on the Prevention and Detection of Money Laundering, Terrorist Financing and Proliferation Financing in the...

Walkers on 9/15/2023

Following industry consultation, on 30 August 2023 the Cayman Islands Monetary Authority ("CIMA") issued updated Guidance Notes on the Prevention and Detection of Money Laundering, Terrorist Financing and Proliferation...more

The SEC Expands Focus on Cybersecurity Risk to Include Registered Advisers, Broker‑Dealers, and other Market Participants

Morrison & Foerster LLP on 4/14/2023

Last month, the SEC took a big step toward strengthening the cybersecurity of financial systems by proposing regulations that, taken together, will require registered investments advisers, broker‑dealers, and all national...more

CFPB Report: ID Theft Among Servicemembers Increasing

Sheppard Mullin Richter & Hampton LLP on 1/27/2023

On January 12, the CFPB released a report that identified an uptick in identity theft reported by servicemembers. The report found that military consumers (defined as active duty servicemembers, veterans, and military family...more

NYDFS Releases Pre-Proposed Second Amendment to its Cybersecurity Regulations, 23 NYCRR 500

Faegre Drinker Biddle & Reath LLP on 9/2/2022

On July 29, 2022, the New York Department of Financial Services (NYDFS) published the pre-proposed second amendment to its Cybersecurity Regulations, 23 NYCRR 500 (Part 500), that if adopted, would likely require numerous...more

Cybersecurity Remains a Key Focus Area for the SEC and FINRA

Goodwin on 6/15/2022

Cybersecurity and technology governance remain a top area of focus for the SEC and FINRA, as the regulators continue to concentrate on improving the overall cybersecurity posture and resiliency of the financial sector. FINRA...more

SEC Proposes Changes to Private Fund Regulation

Goodwin on 2/11/2022

In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed changes to private fund regulation; the Office of the Comptroller of the Currency (OCC) succeeded in validating its “valid-when-made” rulemaking; the...more

SEC to Advisors and Funds – Adopt and Implement Cybersecurity Policies and Procedures

Jackson Lewis P.C. on 2/11/2022

On February 9, the Securities and Exchange Commission (“SEC”) voted to propose rule 206(4)-9 under the Advisers Act and 38a-2 under the Investment Company Act (collectively, “Proposed Rule”). In general, the Proposed Rule...more

SEC Chair Gensler Remarks Indicate 2022 Action Expanding Cyber Requirements

Holland & Knight LLP on 1/31/2022

U.S. Securities and Exchange Commission (SEC) Chair Gary Gensler made remarks on Jan. 24, 2022, at Northwestern University Pritzker School of Law's Annual Securities Regulation Institute regarding the SEC's work to improve...more

SEC Publishes Sample Climate Change Comment Letter

Goodwin on 9/24/2021

In This Issue. The U.S. Securities and Exchange Commission (SEC) published a sample comment letter on climate change disclosures; the Financial Industry Regulatory Authority (FINRA) is conducting a review of brokerage firm...more

NYDFS—First Enforcement Action under Cybersecurity Regulation

McDermott Will & Emery on 7/30/2020

On July 21, 2020, the New York Department of Financial Services (NYDFS) announced that it had filed its first enforcement action under 23 NYCRR 500 (the “Cybersecurity Regulation”) against First American Title Insurance (the...more

UK Conduct Authority Publishes Findings of Review of Risk Modelling and Other Portfolio Management Tools in the Asset Management...

A&O Shearman on 1/24/2020

The U.K. Financial Conduct Authority has published a report on its review of how firms in the asset management sector selected and used risk modelling and other portfolio management tools. The review was undertaken to assess...more

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