Cybersecurity

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Under new SEC leadership, the Division’s 2026 Examination Priorities reflect a modified approach, following a reevaluation of the Division’s risk-based priorities, and a renewed focus on several traditional risk areas (including Regulation Best Interest, adherence to fiduciary standards of conduct, complex products and the Broker-Dealer Financial Responsibility Rules) as well as continued attention to emerging …

In late May 2025, the Securities Industry and Financial Markets Association (SIFMA), together with the American Bankers Association, Bank Policy Institute, Independent Community Bankers of America, and Institute of International Bankers submitted a petition to the Securities and Exchange Commission (SEC) requesting rulemaking to amend its Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure rule…

On March 31, 2025, the U.S. House Financial Services Committee (Committee) penned a letter to acting Securities and Exchange Commission (SEC) Chair Mark Uyeda identifying 14 proposed and final rules that, according to the Committee, should be withdrawn in their entirety. All of the cited rules were proposed or implemented under prior SEC Chair Gary…

The Financial Industry Regulatory Authority, Inc. (“FINRA”) published its 2025 Annual Regulatory Oversight Report (the “Report”), which builds on the structure and content of FINRA’s prior reports for 2021-2024. This year, the Report adds new topics relating to the third-party risk landscape, registered index-linked annuities and extended hours trading. The Report also includes new content…

At the Practising Law Institute’s 56th Annual Institute on Securities Regulation, panelists discussed how public companies are addressing cybersecurity and artificial intelligence (AI) related issues.

Cybersecurity Disclosure Landscape

As cyber threats continue to evolve and challenge companies, the SEC has honed its focus on corporate disclosures related to cybersecurity incidents, risk management, and governance practices. …

On November 13, 2024, during the Practicing Law Institute’s 56th Annual Institute on Securities Regulation, a panel of experts discussed recent disclosure developments for public companies. The main topics of discussion included Insider Trading Policies and 10b5-1 Plans, Non-GAAP Measures, Cybersecurity, and ESG.

Navigating the Updated SEC Rules for 10b5-1 Plans

The SEC’s recent…

Priorities Include Artificial Intelligence and Other Emerging Technologies, Complex Products, Reg BI, Cybersecurity, Outsourcing, Private Funds and Compliance with New and Amended SEC Rules

On October 21, 2024, the Division of Examinations (the “Division”) of the U.S. Securities and Exchange Commission (“SEC”) released its examination priorities for fiscal year 2025 (which started October 1, 2024).