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

Data Matters

In the Order, the SEC alleges that First American’s disclosures concerning the vulnerability were deficient because senior executives were not provided all available and relevant information, specifically that First American’s information security personnel had identified and failed to remediate the vulnerability months earlier in January 2019.

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

Data Matters

On August 11, 2021, the Federal Financial Institutions Examination Council (FFIEC)1 issued guidance establishing risk management principles and practices to support the authentication of users accessing a financial institution’s information systems and customers accessing a financial institution’s digital banking services (the Guidance).