Avi Gesser is a former partner in Davis Polk’s Litigation Department. If you would like to discuss the topics covered in this post, please contact Greg Andres, Robert Cohen, Neil MacBride or visit our Data and Cybersecurity webpage for more information.

In the wake of a highly-publicized cybersecurity breach involving the SEC’s EDGAR system, SEC Chairman Jay Clayton has been in the hot seat at recent congressional hearings, fielding pointed questions as to whether the SEC should delay implementation of the Consolidated Audit Trail (“CAT”).  The SEC has not announced a
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