On November 20, 2025, the Securities and Exchange Commission (SEC) dismissed its landmark enforcement action against SolarWinds Corp. and the company’s Chief Information Security Officer, Tim Brown. In 2023, the SEC’s enforcement action broke new ground as the first formal action by the Commission against a CISO and the first civil fraud action litigated by […]
About Madeleine Juszynski Davidson
SEC Withdraws Proposed Cyber-Related Rule Applicable to Broker-Dealers And Signals SolarWinds Settlement on the Horizon
The Securities and Exchange Commission (SEC) recently announced the withdrawal of several Biden-era regulations, including a proposed rule that would have required a broad range of platforms and financial intermediaries (such as broker-dealers, clearing agencies, national securities exchanges, and transfer agents) to adopt policies and procedures that address cybersecurity risks. The proposed rule also would […]
SEC Settlement Suggests the Agency’s Attempt to Regulate Cybersecurity Controls
On June 18, 2024, the SEC announced a $2.125 million settlement with R.R. Donnelley & Sons Co. (“RRD”) related to the company’s 2021 ransomware attack (the “Incident”). The settlement, and the SEC’s accompanying cease-and-desist order (the “Order”), portend the agency’s continued and increasing oversight over registrants’ cybersecurity policies and practices. Background RRD is a global […]
California Federal Court Dismisses Data Security-Related Securities Fraud Class Action
A California federal court has dismissed a putative securities fraud class action alleging that a large title insurer that disclosed a data security incident in May 2019 made false and misleading statements related to its data security practices and the incident. The dismissal follows the June 2021 settlement of a related Securities & Exchange Commission […]