John J. Cooney

DFS and SEC Warn Financial Entities of Heightened Cybersecurity Risk

Both the New York State Department of Financial Services (“DFS”) and the¬†Securities and Exchange Commission (“SEC”) have warned financial entities that Russia’s invasion of Ukraine will likely result in an elevated number of cyber-attacks and…

SEC Votes to Propose Rules For Cybersecurity Concerning RIAs

As discussed in the prior update, the Securities and Exchange Commission (SEC), and specifically the Chair of the SEC, Gary Gensler, emphasized the SEC‚Äôs cybersecurity focus during his address at the 2022 Annual Securities Regulation…

SEC Provides More Insight into 2022 Plans

As discussed¬†in prior updates, the Securities and Exchange Commission (SEC)¬†has increased its efforts with regard to cybersecurity.¬† Towards that end, Chair of the SEC, Gary Gensler, discussed the SEC‚Äôs cybersecurity focus during his address¬†at the…

Capital One Hacks

In the summer of 2019, Capital One discovered that a hacker had accessed private data for more than 100 million Capital One customers, including data that was part of their credit card applications, such as…

Cybersecurity Focus for SEC Will Continue for 2022

In past posts, we discussed increased enforcement efforts by the¬†Securities and Exchange Commission (SEC).¬†The SEC‚Äôs focus should have come as no surprise given that in early 2021, the SEC¬†highlighted information protection and cybersecurity as key…

The SEC Strikes Again

In the last newsletter, we discussed the¬†Securities and Exchange Commission (SEC)¬†and its recent enforcement efforts.¬† ¬†Specifically, how the SEC and the New York Department of Financial Services (DFS) have been pursuing entities for failure to…

Look Out, Here Comes the SEC

In the last few posts, we discussed the¬†NYS Department of Financial Services (“DFS”) and its enforcement efforts.¬† ¬†Specifically, NY DFS has been going after entities for failure to report prior breaches.   For example, DFS…

A Deeper Look at the Criteria for Reporting a Breach to NYDFS

In the last newsletter, we discussed the¬†NYS Department of Financial Services (“DFS”) recent efforts and its overall posture of ramping up enforcement.¬† One of the important points that we noted was that the hefty multi-million…

Critical Point in Recent NYS DFS Enforcement Actions

In the last post, it was noted that the NYS Department of Financial Services (“DFS”) was ramping up enforcement of its Cybersecurity Regulation as evidenced by two recently announced multi-million dollar settlements.¬† One of the…

NYDFS Ramps Up Enforcement Actions

The NYS Department of Financial Services (“DFS”) has recently announced two multi-million dollar settlements and has increased enforcement of its Cybersecurity Regulation. It is important to note that DFS has announced three enforcement actions since…