Ms. Clark is an associate in Davis Polk's Litigation Department. [Full Bio]

In our first Cyber Blog post, we predicted that the rules-based approach adopted by the NYDFS would become the model for cybersecurity regulation.  Two years later, we’re feeling pretty good about that prediction, as the FTC recently proposed incorporating a number of aspects of the NYDFS cybersecurity rules into
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On April 1, 2019, new cybersecurity requirements outlined in the NFA’s Interpretive Notice to NFA Compliance Rules 2-9, 2-36 and 2-49 will come into effect.  These new requirements apply to NFA Members, including registered futures commission merchants, commodity trading advisors, commodity pool operators, introducing brokers, retail foreign exchange dealers, and
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The Davis Polk Cybersecurity Team recently blogged about the breach of the SEC’s EDGAR database:

“…The SEC does not believe that personally identifiable information was exposed, but the investigation is still ongoing and raises questions regarding government agencies’ obligations to protect sensitive information, and the potential litigation challenges facing individuals


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