COMPLIANCE CORNER

Cyber Regulations & Compliance Challenges

Deciphering the landscape to understand the evolution of cybersecurity regulations and compliance

FCI Compliance Corner

Compliance & Enforcement

With over a combined 25 years of business, legal, and technical experience, The Law Office of John J. Cooney, P.C. offers comprehensive legal strategies and solutions for businesses working seamlessly with management and any existing counsel in an efficient manner. John’s firm concentrates on General Counsel services, Pre-Litigation Investigation, Defense, and Compliance services, as well as the Cybersecurity Regulations arena.

John J. Cooney, Esq

SEC Adopts Proposed Cybersecurity Disclosure Rules

As you know, the Securities and Exchange Commission (SEC)  has been working on new cybersecurity disclosure rules for over a ...
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$37.5 Million Dollars and the SEC’s Continued Focus on Off Channel Communications

In early May 2023, The Securities and Exchange Commission (SEC) announced a large enforcement action against broker dealers HSBC Securities ...
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FINRA’s Guidance and Insights Concerning Cybersecurity

Earlier this year, the Financial Industry Regulatory Authority (“FINRA”) published its 2023 Report on FINRA’s Examination and Risk Monitoring Program ...
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SEC Rule Nearing Implementation

Although the last few updates have concerned the New York Department of Financial Services (“DFS”) and its proposed amendments to ...
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2023 and DFS Proposed Amendments

As discussed prior, in late 2022 the New York Department of Financial Services (“DFS”) published proposed amendments to its Cybersecurity ...
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The New York Department of Financial Services Cybersecurity Regulation Proposed Amendments

The New York Department of Financial Services (“DFS”) recently released a proposed second amendment to the Cybersecurity Regulation, 23 NYCRR ...
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Preserving Attorney Client Privilege For Cybersecurity Vulnerabilities

Firms should be aware of making potential admissions when assessing their cybersecurity risks, including when investigating an actual data breach.  ...
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Cybersecurity Insurance Developments

The cybersecurity insurance market continues to evolve and there are some important developments for your consideration.  In short, although cybersecurity ...
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SEC Proposes New Cybersecurity Rules

As you may remember, earlier this year the Securities and Exchange Commission (SEC) voted to propose cybersecurity rules and amendments ...
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SEC Examinations Division Names Cybersecurity as a 2022 Exam Priority

Recently, the Division of Examinations of the Securities and Exchange Commission (the “SEC”) released its annual list of examination priorities ...
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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 ...
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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 ...
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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, ...
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Capital One Hacks

In the summer of 2019, Capital One discovered that a hacker had accessed private data for more than 100 million ...
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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’s focus should have come as ...
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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 ...
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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 ...
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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 ...
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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 ...
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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 ...
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