On December 8, 2022, the Division of Corporation Finance within the Securities and Exchange Commission (“SEC”) published guidance on disclosure obligations related to recent disruptions in the crypto asset market. The Sample Letter to Companies Regarding Recent Developments in Crypto Asset Markets aims to improve compliance with disclosure obligations under SEC regulations.
Federal law requires
Yesterday, on August 24, 2022, California Attorney General Rob Bonta (“AG”) announced a settlement with Sephora, Inc., resolving allegations that the company violated the California Consumer Privacy Act (“CCPA”). The order includes permanent injunctive relief as well as a $1.2 million fine. This action stems from a June 2021 enforcement sweep by the attorney general
The Department of Justice (“DOJ”), on behalf of the Federal Trade Commission (“FTC”), filed a complaint and motion for entry of a stipulated order with the Northern District of California, which would require Twitter to pay civil penalties and take other corrective actions for their violation of the FTC Act and a previous 2011 FTC
On August 30, 2021, the Securities and Exchange Commission (SEC) sanctioned eight firms in three actions for cybersecurity failures in their policies and procedures that exposed the personal information of thousands of customers at each firm. These firms included: Cetera Advisor Networks LLC, Cetera Investment Services LLC, Cetera Financial Specialists LLC, Cetera Advisors LLC,
On March 17, 2021, Governor Gavin Newsome, Attorney General Xavier Becerra, Senate President pro tem Toni Atkins, and Assembly Speaker Anthony Rendon announced the members of the California Privacy Protection Agency (CPPA) the new administrative agency created by the California Privacy Rights Act (CPRA) charged with protecting consumer privacy rights overs personal information.
“Californians deserve
On October 7, 2020, The Office of the Comptroller of the Currency (“OCC”) announced that it had assessed a $400 million civil penalty against Citibank, N.A. regarding alleged deficiencies in its enterprise-wide risk management and data governance programs and its internal controls. In particular, the OCC found violations of 12 CFR Part 30, Appendix D
On June 1, 2020, California Attorney General Xavier Becerra submitted a finalized package of CCPA regulations to the California Office of Administrative Law (OAL). The package included not only the final text of the regulations, but also the final statement of reasons for amendments to the previous drafts. There have been multiple rounds of drafts
On May 4, the Californians for Consumer Privacy (led by Alistair McTaggart, the real estate investor and activist behind the original ballot initiative that led to the CCPA), announced in a letter that it had collected over 900,000 signatures to qualify the California Privacy Rights Act (“CPRA”) for the November 2020 ballot. This version of
On March 18, 2020, the Federal Energy Regulatory Commission (FERC) and the North American Electric Reliability Corporation (NERC) announced steps to ensure that operators of the bulk electric system can focus resources on safety and reliability during the COVID-19 emergency. FERC and NERC are advising all registered entities that they will consider the impact of
On December 6, 2019, the FTC issued an opinion finding that Cambridge Analytica, they had engaged in deceptive practices to collect personal information from several users of Facebook for purposes of voter profiling and targeting. In addition, the Commission found that Cambridge Analytica had engaged in deceptive practices regarding its participation in the EU-US Privacy
