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Amy Greer

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As predicted in our Connect on Tech discussion in March, the U.S. Securities and Exchange Commission (“SEC”) is ramping up its examination and enforcement focus on cybersecurity at financial institutions, including scrutiny on actual implementation and deployment of published procedures in response to discovery of cyber breach incidents. Furthermore, the SEC appears to signal its expectation that multi-factor authentication (“MFA”) for email accounts containing sensitive client and customer information should be in place. Email Account…

The Securities and Exchange Commission fined a real estate services company for inadequate disclosure controls and procedures violations related to a cybersecurity vulnerability that exposed hundreds of thousands of sensitive customer records. Background In 2019, a cybersecurity journalist discovered and notified the real estate services company about a vulnerability with its document and images sharing app that exposed over 800 million images dating back to 2003, including documents that contained sensitive personal information such as…

On January 7, 2020, the U.S. Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) announced its 2020 Examination Priorities that included cybersecurity practices. Soon after the publication of the OCIE Examination Priorities, on January 27, 2020, OCIE followed-up with a report entitled Cybersecurity and Resiliency Observations These two OCIE releases, along with prior SEC alerts and actions, provide strong indications that the SEC, in 2020, will be ramping up its focus…