We may now have more clarity on what the California Consumer Privacy Act (the “CCPA”) will look like when it goes into effect on January 1, 2020. The California Assembly’s Committee on Privacy and Consumer Protection approved a series of bills last week that will now advance to the Appropriations Committee before being put to […]
Regulation
SEC Issues Risk Alert Noting Common Regulation S-P Compliance Issues
The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) has issued a Risk Alert that provides an overview of the most common deficiencies or weaknesses in investment adviser and broker-dealer compliance with the Safeguards Rule, Regulation S-P, based on recent examinations. Placed in context with prior OCIE Risk Alerts concerning cybersecurity practices and Regulation S-P […]
The Coming Regulation of Artificial Intelligence? EU Publishes AI Guidelines
The European Commission High-Level Expert Group on Artificial Intelligence released on April 8, 2019 the final version of its Ethics Guidelines for Trustworthy AI (the “Guidelines”). This is the first significant guidance issued in Europe regarding Artificial Intelligence and follows an extensive public comment process. While the Guidelines are not binding law, the creation of the […]
FTC Announces New Cybersecurity Requirements, Privacy Rule Update
In March, the Federal Trade Commission announced proposed updates to two key privacy and security regulations, the Safeguards Rule and Privacy Rule. Both rules implement regulations under the federal Gramm Leach Bliley Act, and the FTC seeks comments for both. The FTC’s proposed update to the Safeguards Rule would impose a number of information security […]
Companion Cybersecurity Disclosure Bills Introduced in U.S. Congress
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 […]