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Valerie Mirko

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In Cybersecurity

SEC Proposes Broad New Cybersecurity Risk Management Rules for Investment Advisers and Funds

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Commission Seeks Public Comment on Wide Range of Issues in Proposal On February 9, 2022, the Securities and Exchange Commission (SEC or Commission) voted 3-1, with Commissioner Peirce, the lone remaining Republican appointee opposed, to propose new rules under the Investment Advisers Act of 1940 (Advisers Act) and the Investment Company Act of 1940 (Investment Company Act) related to cybersecurity risk management, reporting of breach events, and recordkeeping for registered investment advisers and investment funds.1 If…

In Financial Institutions

SEC Ramping Up Examination and Enforcement Scrutiny of Cybersecurity at Financial Institutions

by , , , and 3 Mins Read

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…

In Podcast

Podcast Episode 30 — Cybersecurity and the SEC: Looking Forward Following Market Turmoil

by , and 1 Min Read

Partners Peter Chan and Valerie Mirko join Brian Hengesbaugh to discuss the SEC and cybersecurity, leveraging their own experiences with the agency to give an overview of the past, present and future. Listen to learn about: The evolution of the SEC’s focus on cybersecurity, particularly with regard to financial institutionsAn insider’s take on what may trigger SEC investigationWhat’s in store with the Biden administration and how companies should prepare https://open.spotify.com/episode/5Z4nHbjxtrntljyEBMRRqF?si=J3ucfdTRQF6lArxRf540FA Related Resources: SEC Announces 2021…

In Data Privacy

SEC Signals Heightened Scrutiny of Cybersecurity Practices

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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…