Greenberg Traurig Shareholder, Jena M. Valdetero, U.S. Co-chair of the Data Privacy & Cybersecurity Group, will present the Strafford webinar, “SEC Cybersecurity Enforcement Authority After SolarWinds Ruling: Mitigating Exposure to Securities Fraud Liability,” on Oct. 9. This webinar will discuss the important cybersecurity points. Including the Southern District of New York’s ruling
Greenberg Traurig Expands White Collar Defense & Investigations Practice with Addition of Former SEC Regional Director Tracy S. Combs
Global law firm Greenberg Traurig, LLP continues the expansion of its White Collar Defense & Investigations Practice with the addition of Tracy S. Combs in the San Francisco office. During Combs’ eight-year tenure at the Securities & Exchange Commission (SEC), she served in a variety of roles in Salt Lake City and San Francisco…
EVENT | CISO Summit at Black Hat USA 2024
Greenberg Traurig Shareholder Tracy Combs spoke at the CISO Summit at Black Hat USA 2024 in a session titled “Navigating the Regulatory Landscape: A Fireside Chat on SEC Actions and Corporate Responses” Tuesday, Aug. 6. The event, tailored for chief information security officers (CISOs) and senior security executives, focused on providing insights into…
SEC v. SolarWinds Update: U.S. Federal District Court Dismisses Most of the SEC’s Case, but Some Fraud Claims and CISO Liability Remain
A U.S. district court dismissed all the SEC’s securities fraud and false filings claims against SolarWinds and its Chief Information Security Officer (CISO) Timothy Brown regarding the adequacy of cyberattack disclosures, finding that the SEC had impermissibly relied on “hindsight and speculation” to find those disclosures fraudulent. The court also dismissed the SEC’s claims that…
SEC Adopts Cybersecurity Amendments to Regulation S-P
On May 16, 2024, the U.S. Securities and Exchange Commission finalized amendments to Regulation S-P (the Amendments) that largely adopt the proposed amendments the SEC issued in 2023. As discussed in further detail below, the Amendments will require broker-dealers, investment companies, SEC-registered investment advisers, funding portals, and transfer agents registered with the SEC or other…
SEC Clarifies Confusion Concerning Cybersecurity Incident Reporting
On May 21, 2024, U.S. Securities and Exchange Commission Director of the Division of Corporation Finance Erik Gerding issued a statement clarifying when the SEC expects companies to disclose a cyber incident. This clarification helps guide public companies who wish to disclose a cyber incident but who have not yet determined if the incident is…
5 Trends Under SEC’s New Cybersecurity Incident Disclosure Rule
Since the Securities and Exchange Commission’s Cybersecurity Incident Disclosure Rule (SEC Rule) took effect Dec. 18, 2023, about a dozen companies have filed a Form 8-K reporting a material cybersecurity incident. This GT Alert discusses the trends on how companies have made these disclosures thus far. In short, the companies who have filed an 8-K…
Jena M. Valdetero and Steven M. Malina Quoted in Dark Reading Article, ‘Orgs Face Major SEC Penalties for Failing to Disclose Breaches’
Jena M. Valdetero, Co-Chair of the firm’s Data Privacy and Cybersecurity Practice, and Steven M. Malina, a member of GT’s Litigation Practice, were quoted in a Dark Reading article titled “Orgs Face Major SEC Penalties for Failing to Disclose Breaches.”
Click here to read the full article, published by Dark Reading
DOJ Issues New Guidelines on National Security Exception for SEC Required Disclosure of Material Cybersecurity Incidents
As detailed in our July 2023 GT Alert, the Securities and Exchange Commission (SEC) now requires public companies to file a Form 8-K and disclose a material cybersecurity incident within four days of determining the incident’s materiality. Form 8-K Item 1.05(c) includes an exception to the four-day requirement: where disclosure poses a substantial risk…
Dec. 1 WEBINAR | Keeping up with the SEC: Unpacking the New Public Company Cybersecurity Rule and Enforcement
Greenberg Traurig Shareholders Jena M. Valdetero, Co-Chair of the U.S. Data Privacy & Cybersecurity Practice, and Steven M. Malina will present the Thomson Reuters West LegalEdcenter and Celesq webinar, “Keeping up with the SEC: Unpacking the New Public Company Cybersecurity Rule and Enforcement,” on Friday, Dec. 1 at 12:00 p.m. EST.
This…