Anna Moody – Debevoise Data Blog

Artificial Intelligence

Top 10 SEC Cyber/AI Blog Posts for 2024

By: Andrew J. Ceresney, Charu A. Chandrasekhar, Luke Dembosky, Avi Gesser, Eric T. Juergens, Arian June, Robert B. Kaplan, Erez Liebermann, Sheena Paul, Benjamin R. Pedersen, Marc Ponchione, Jeff Robins, Paul Rodel, Julie M. Riewe, Kristin Snyder, Jonathan R. Tuttle, Phil Fortino, Matt Kelly, Anna Moody, Stephan J. Schlegelmilch, Johanna Skrzypczyk, Suchita Mandavilli Brundage, Kelly Donoghue, Andreas A. Glimenakis, Alice Gu, John Jacob, Gabriel Kohan, Talia Lorch, Ciera Mandelsberg, Noah L. Schwartz, Ned Terrace and Mengyi Xu December 12, 2024

As we approach the end of the year, here are the Top 10 SEC Cyber/AI posts on the Debevoise Data Blog in 2024 by page views. If you are not…

Enforcement

SEC Charges Four Companies for Misleading Cyber Disclosures

By: Andrew J. Ceresney, Charu A. Chandrasekhar, Luke Dembosky, Erez Liebermann, Benjamin R. Pedersen, Julie M. Riewe, Matt Kelly, Anna Moody, Kelly Donoghue, Ciera Mandelsberg and Noah L. Schwartz October 28, 2024

On October 22, 2024, the U.S. Securities and Exchange Commission (the “SEC”) announced settled charges in separate actions against four technology companies—Avaya Holdings Corp. (“Avaya”), Check Point Software Technologies Ltd.…

Cybersecurity

HUD Proposes to Narrow its Cyber Incident Notification Requirement

By: Avi Gesser, Erez Liebermann, Anna Moody, Stephanie Thomas and Karen Joo October 10, 2024

Earlier this year, the U.S. Department of Housing and Urban Development (“HUD”) released an unannounced and immediately effective Cyber Incident Reporting Requirement (the “Original Requirements”) in Mortgagee Letter 2024-10, which…

Cybersecurity

Internal Accounting Controls Claim Rejected in SolarWinds Case

By: Andrew J. Ceresney, Charu A. Chandrasekhar, Luke Dembosky, Erez Liebermann, Benjamin R. Pedersen, Julie M. Riewe, Paul Rodel, Matt Kelly, Anna Moody, Alice Gu and Talia Lorch July 23, 2024

On July 18, 2024, in the landmark SEC v. SolarWinds Corp. case, U.S. District Judge Paul Engelmayer dismissed the majority of the claims brought by the U.S. Securities and Exchange Commission (the…

Business

SEC Releases New Guidance on Material Cybersecurity Incident Disclosure

By: Paul Rodel, Benjamin R. Pedersen, Erez Liebermann, Eric T. Juergens, Anna Moody, John Jacob and Kelly Donoghue June 27, 2024

June 27, 2024 On June 24, 2024, the staff of the Division of Corporation Finance of the Securities and Exchange Commission (the “SEC”) released five new Compliance & Disclosure Interpretations…

Cybersecurity

Incident Response Plans Are Now Accounting Controls? SEC Brings First-Ever Settled Cybersecurity Internal Controls Charges

By: Andrew J. Ceresney, Charu A. Chandrasekhar, Luke Dembosky, Avi Gesser, Erez Liebermann, Benjamin R. Pedersen, Julie M. Riewe, Matt Kelly, Anna Moody and Andreas A. Glimenakis June 20, 2024

In an unprecedented settlement, on June 18, 2024, the U.S. Securities & Exchange Commission (the “SEC”) announced that communications and marketing provider R.R. Donnelley & Sons Co. (“RRD”) agreed to…

Cybersecurity

Very Broad and Very Fast: The New Federal Housing Administration’s 12-Hour Cyber Incident Notification Rule

By: Courtney M. Dankworth, Avi Gesser, Satish Kini, Erez Liebermann, Gregory Lyons, Matt Kelly, Anna Moody, Jehan A. Patterson, Alexandra Mogul, Michelle Huang and Karen Joo May 28, 2024

On May 23, 2024, the U.S. Department of Housing and Urban Development (“HUD”) announced that, effective immediately, Federal Housing Administration (“FHA”)-approved Mortgagees are subject to a drastically heightened cybersecurity incident…

Cybersecurity

The SEC Adopts Significant Cybersecurity Amendments to Reg S-P

By: Charu A. Chandrasekhar, Luke Dembosky, Avi Gesser, Erez Liebermann, Sheena Paul, Marc Ponchione, Julie M. Riewe, Jeff Robins, Kristin Snyder, Anna Moody, Johanna Skrzypczyk, Suchita Mandavilli Brundage and Ned Terrace May 17, 2024

On May 16, 2024, the SEC adopted amendments to Regulation S-P (“Reg S-P”) one year after its proposed amendments (the “Proposed Amendments”). The finalized amendments (“Amended Reg S-P”) largely track…

Cybersecurity

100 Days of Cybersecurity Incident Reporting on Form 8-K: Lessons Learned

By: Charu A. Chandrasekhar, Erez Liebermann, Benjamin R. Pedersen, Paul Rodel, Matt Kelly, Anna Moody, John Jacob, Kelly Donoghue and Talia Lorch March 28, 2024

On December 18, 2023, the Securities and Exchange Commission’s (the “SEC”) rule requiring disclosure of material cybersecurity incidents became effective. To date, 11 companies have reported a cybersecurity incident under…

Artificial Intelligence

AI Enforcement Starts with Washing: The SEC Charges its First AI Fraud Cases

By: Andrew J. Ceresney, Charu A. Chandrasekhar, Avi Gesser, Arian June, Robert B. Kaplan, Julie M. Riewe, Jeff Robins, Kristin Snyder, Jonathan R. Tuttle, James Amler, Phil Fortino, Matt Kelly, Anna Moody, Stephan J. Schlegelmilch, Gabriel Kohan and Corey Goldstein March 19, 2024

On March 18, 2024, the U.S. Securities and Exchange Commission (“SEC”) announced settled charges against two investment advisers, Delphia (USA) Inc. (“Delphia”) and Global Predictions Inc. (“Global Predictions”) for making…