On February 28 and March 13, 2019, members of the U.S. Senate and U.S. House of Representatives introduced legislation designed to enhance the transparency of cybersecurity risk oversight at certain SEC reporting companies. Although the text of the House bill, H.R. 1731 is not yet publicly available, the bipartisan Senate bill, S. 592, would require […]
NYDFS Cybersecurity Regulations Nearly Fully Effective
The February 15, 2019 NYDFS compliance certification deadline represents the last annual compliance certification subject to the transition period for covered entities to come into compliance with the cybersecurity regulations. NYDFS now expects covered entities to certify as to their compliance with all but one provision of the cybersecurity regulations which relates to the implementation […]
HHS Releases New “Health Industry Cybersecurity Practices”
On December 28, 2018, the Department of Health and Human Services (HHS) issued new voluntary cybersecurity guidance for the health care industry titled, “Health Industry Cybersecurity Practices: Managing Threats and Protecting Patients.” This four-volume set of consensus-based principles and practices (the “HICP”) reflects the recommendations of the 405(d) Task Group, a HHS and industry-led collaborative […]
Michigan Enacts Insurance Data Security Model Law
Michigan enacted the Michigan Data Security Act on December 28, 2018, imposing stringent cybersecurity measures on any person (individual or corporate) licensed by the Michigan Department of Insurance and Financial Services. Based on the 2017 NAIC data security model law and nearly identical to the South Carolina Insurance Data Security Act, the Michigan statute will […]
SEC Investigative Report Cautions Public Companies to Consider Cyber Threats When Implementing Internal Accounting Controls
The Securities and Exchange Commission issued an investigative report last week cautioning public companies to consider cyber incidents and threats when implementing internal accounting controls. The report details the SEC Enforcement Division’s investigations of nine public companies that were victims of cyber-related fraud schemes to determine whether the companies may have violated the federal securities […]