Micaela McMurrough

Micaela McMurrough

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The Securities and Exchange Commission and Financial Industry Regulatory Authority Release Examination Priorities for 2017

The Securities and Exchange Commission’s (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”) and the Financial Industry Regulatory Authority, Inc. (“FINRA”) (a private self-regulatory organization overseen by OCIE), recently released their 2017 examination priorities.  It is no surprise to find cybersecurity listed as an examination priority again this year. OCIE and FINRA have repeatedly recognized … Continue Reading

Extension of Time for Comments on the Federal ANPR on Cyber Risk Management Standards

For those considering submitting comments on the federal advance notice of proposed rulemaking (ANPR) on enhanced cyber risk management standards, you’ve been granted an extension.  The agencies involved—the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation—announced that they will extend the comment period … Continue Reading

Reports Suggest New York DFS to Revise Proposed Cyber Regulations and Delay Implementation

Based on reports citing New York Department of Financial Services (“DFS”) sources (see here and here), DFS may propose a revised version of its first-in-the-nation cybersecurity regulations on December 28, 2016.  That revision would be followed by a new 30-day comment period, with the revised regulations scheduled to take effect on March 1, 2017. This … Continue Reading

Industry Reacts to New York’s Proposed Cybersecurity Regulation for Financial Services Institutions

On December 19, 2016, the New York State Assembly Standing Committee on Banks heard testimony about a proposed regulation introduced by the New York State Department of Financial Services that would require financial services companies to develop and implement cybersecurity programs to defend against cyber-attacks.  As we covered when Governor Andrew Cuomo announced this first-in-the-nation … Continue Reading

New York State Proposes Cybersecurity Regulation for Financial Services Institutions

On September 13, 2016, New York Governor Andrew Cuomo announced a proposed regulation that would require financial service institutions to develop and implement cybersecurity programs to prevent and mitigate cyber-attacks.  The proposed regulation will be subject to a 45-day comment period once it is published in the New York State Register. The regulation will become … Continue Reading
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