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SEC Announces Settled Charges Against First American for Cybersecurity Disclosure Controls Failures – Lessons Learned

Data Matters

On June 15, 2021, the SEC announced settled charges against First American Title Insurance Company (First American) for disclosure controls and procedures violations related to a cybersecurity vulnerability that exposed sensitive customer information. provide for open communications between technical experts and disclosure advisers.

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UK FCA Consults on Changes to Strong Consumer Authentication, Dedicated Interfaces, and Guidance on Payment Services

Data Matters

This follows the FCA’s announcement in its 2020-21 business plan that payment services were one of its main supervisory priorities 1 and its temporary guidance of July 9, 2020, on prudential risk management and safeguarding in light of the COVID-19 pandemic ( Temporary COVID Guidance ). its Perimeter Guidance Manual (PERG).

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FFIEC Guidance on Authentication and Access to Financial Institution Services and Systems

Data Matters

The Guidance replaces prior FFIEC-issued guidance on risk management practices for financial institutions offering internet-based products: “Authentication in an Internet Banking Environment” (2005) and the “Supplement to Authentication in an Internet Banking Environment” (2011).

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An Approach to Cybersecurity Risk Oversight for Corporate Directors

Data Matters

Per the SEC’s recent disclosure guidance, among other things, the effectiveness of disclosure controls and procedures are tied to an organization’s ability to enhance communications between technical experts and disclosure advisors on data management processes that may address such risks. Principle 5.