Charu A. Chandrasekhar – Page 5 – Debevoise Data Blog

Cybersecurity

A Late Winter Blizzard of SEC Cybersecurity Rulemaking: the Proposed BD Cybersecurity Rules and Expanded Reg S-P and Reg SCI Obligations

By: Luke Dembosky, Avi Gesser, Erez Liebermann, Marc Ponchione, Julie M. Riewe, Jeff Robins, Kristin Snyder, Charu A. Chandrasekhar, Sheena Paul, Suchita Mandavilli Brundage, Michael R. Roberts, Mengyi Xu and Ned Terrace March 20, 2023

On March 15, 2023, the U.S. Securities and Exchange Commission (the “SEC”) released a suite of proposed new rules (the “Proposed Rules”) that include: Proposed new cybersecurity rules for broker-dealers,…

Cybersecurity

Preparing for the SEC’s Cybersecurity Rules for Registered Investment Advisers, Registered Investment Companies, and Business Development Companies

By: Luke Dembosky, Avi Gesser, Erez Liebermann, Julie M. Riewe, Kristin Snyder, Charu A. Chandrasekhar, Suchita Mandavilli Brundage and Jarrett Lewis March 13, 2023

In February 2022, the SEC proposed its first-ever cybersecurity rules for registered investment advisers (“RIAs”) (including RIAs to private funds) and Funds (which include registered investment companies (“RICs”) and closed-end…

Regulation

DOJ Issues Trio of Updates that Further Heighten Compliance Expectations, Particularly Involving Off-System Communications and Compensation Systems

By: Kara Brockmeyer, Andrew M. Levine, David A. O'Neil, Kristin Snyder, Bruce Yannett, Charu A. Chandrasekhar, Andreas A. Glimenakis and Joseph Ptomey March 6, 2023

On March 2 and 3, 2023, the U.S. Department of Justice (“DOJ”) announced several updates to its corporate enforcement policies, in significant part formalizing recent pronouncements about corporate compliance programs.…

Cybersecurity

Report Underscores FINRA’s Focus on Cybersecurity

By: Avi Gesser, Erez Liebermann, Kristin Snyder, Charu A. Chandrasekhar and Michael R. Roberts January 18, 2023

On January 10, 2023, the Financial Industry Regulatory Authority (“FINRA”) published its 2023 Report on FINRA’s Examination and Risk Monitoring Program (the “Report”), which is intended to provide member firms…

SEC

Recent SEC EXAMS Risk Alert Highlights Key Considerations for Reg S-ID Compliance

By: Avi Gesser, Erez Liebermann, Kristin Snyder, Charu A. Chandrasekhar, Michael R. Roberts and Noah L. Schwartz December 14, 2022

On December 5, 2022, the Securities and Exchange Commission (the “SEC”) Division of Examinations (“EXAMS”) published a Risk Alert providing observations from recent examinations relating to investment adviser and broker-dealers’…

Enforcement

Lessons from the SEC’s Most Recent Reg S-P Action

By: Avi Gesser, Kristin Snyder, Erez Liebermann, Charu A. Chandrasekhar, Johanna Skrzypczyk and Scott M. Caravello October 6, 2022

On September 20, 2022, the SEC announced settled charges and the imposition of a $35 million penalty against a dually registered investment adviser and broker-dealer (the “Firm”) for violations of Regulation…

NYDFS

NYDFS Proposes Significant Changes to Its Cybersecurity Rules (Part 2) – Answers to the Top 10 Questions from Our Webcast

By: Eric Dinallo, Luke Dembosky, Avi Gesser, Erez Liebermann, Caroline Novogrod Swett and Charu A. Chandrasekhar August 8, 2022

On July 29, 2022, the New York Department of Financial Services (“NYDFS”) released Draft Amendments to its Part 500 Cybersecurity Rules. We provided our initial thoughts on the Draft Amendments…

Cybersecurity

Recent SEC Enforcement Actions Signal Key Lessons for Reg S-ID Compliance

By: Avi Gesser, Erez Liebermann, Kristin Snyder, Charu A. Chandrasekhar, Michael R. Roberts and Noah L. Schwartz August 2, 2022

On July 27, 2022, the Securities and Exchange Commission (“SEC”) separately charged three financial institutions with violations of Rule 201 of Regulation S-ID (“Reg S-ID”), also known as the Identity…

Cybersecurity

Webcast on NYDFS Draft Amendments to Part 500 Cybersecurity Rules

By: Eric Dinallo, Luke Dembosky, Avi Gesser, Erez Liebermann and Charu A. Chandrasekhar August 2, 2022

On Friday, August 5, 2022, Eric Dinallo, Luke Dembosky, Avi Gesser, Erez Liebermann, and Charu Chandrasekhar participated in a webcast on the proposed draft amendments to the NYDFS cyber rules.…

NYDFS

NYDFS Proposed Significant Changes to Its Cybersecurity Rules

By: Luke Dembosky, Avi Gesser, Erez Liebermann, Jim Pastore, Charu A. Chandrasekhar, HJ Brehmer, Michelle Huang and Mengyi Xu August 1, 2022

On July 29, 2022, the New York Department of Financial Services (“NYDFS”) released Draft Amendments to its Part 500 Cybersecurity Rules, which include a mandatory 24-hour notification for cyber ransom…