The SEC has just stepped up its enforcement efforts for cyber-related disclosure failures by public companies — bigtime.
To date, given the dearth of SEC enforcement actions charging cyber-related disclosure failures, commentators typically cite the SEC enforcement action against Altaba, formerly known as Yahoo!, as the most pertinent precedent and guide for heedful corporate disclosure counsel. But with the announcement of a recent pair of SEC cyber-related administrative actions, one involving a cyber-attack upon an educational services company and the other involving a cyber vulnerability at a financial services firm, the SEC has not only moved the playing field – but has also begun a whole new ballgame.
‘Enforcement 40’ for 2020
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