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On March 21, 2022, the U.S. Securities and Exchange Commission (SEC or Commission) issued its long-awaited proposed ruleset (Rule Proposal) that, if adopted as currently drafted, would mandate both domestic and foreign registrants to make a variety of climate-related impact and risk disclosures in registration statements and in annual filings under the Securities Exchange Act of 1934 (Exchange Act).

On March 17, 2022, FINRA issued Regulatory Notice 22-10 clarifying the scope of potential liability for CCOs related to supervision lapses. Specifically, unless a CCO is actually designated, directly or indirectly, with supervisory responsibilities, within the meaning of the relevant rule, supervision failures or deficiencies will not result in a FINRA enforcement action against a CCO.

In this episode, Daniela Fonseca Puggina, partner in our Miami office and Jennifer Ancona Semko, a partner in our Washington, D.C. office discuss litigation readiness for financial institutions (FIs). The episode also covers potential vulnerabilities and disputes that they need to prepare for, current and emerging trends in litigation (from our Litigation Intelligence: Ready for Anything? Report), and how they can benefit from litigation preparedness.

As predicted in our Connect on Tech discussion in March, the U.S. Securities and Exchange Commission (“SEC”) is ramping up its examination and enforcement focus on cybersecurity at financial institutions, including scrutiny on actual implementation and deployment of published procedures in response to discovery of cyber breach incidents. Furthermore, the SEC appears to signal its expectation that multi-factor authentication (“MFA”) for email accounts containing sensitive client and customer information should be in place.