Like many people, Aaron Graham and Eric Jordan carried cell phones around in 2011. Unlike most people, Graham and Jordan were convicted of crimes arising from their participation in a series of armed robberies [1] in that period, and were soon sorry...(read more)
SEC Enforcement Lays out Approach to Cybersecurity Cases
If you’ve ever attended the SEC Speaks conference, you know that the official program is an intensely uninteresting collection of short speeches by SEC officials who don’t have a lot of incentives to say groundbreaking things. But occasionally there...(read more)
How to Talk to Management about a Privacy Assessment
We’ve discussed the importance of privacy assessments here in the past. It is a frustrating realization, indeed, when a company discovers a data breach involving data that it never needed or even knew it kept. A proactive company-wide privacy...(read more)
SEC Says No More Mr. Nice Guy on Investment Adviser Cybersecurity
Over the last couple years, the SEC’s cybersecurity bark has been worse than its bite. Its Office of Compliance, Inspections, and Examinations issued examination priorities in 2014. Commissioner Aguilar warned public company boards that they had...(read more)
FCC Stakes Out Privacy Territory in Broadband Privacy Workshop
If you thought all the action in privacy regulation centered around the Federal Trade Commission, the Federal Communications Commission would like you to think again. Yesterday, April 28, the FCC held a 3-plus hour workshop that started the...(read more)
FTC Commissioner Comments on Consumer Privacy Bill of Rights
Last week, we posted about the Consumer Privacy Bill of Rights “discussion draft” released by the Obama Administration. On Thursday, March 5, at the annual U.S. meeting of the International Association of Privacy Professionals (which I attended),...(read more)
Two-Factor Authentication May Be Coming to a Bank Near You
Ed. Note: This entry is cross posted from Cady Bar the Door , David Smyth's blog offering Insight & Commentary on SEC Enforcement Actions and White Collar Crime. When I was at the SEC and online broker-dealers’ customers were the victims of...(read more)