1. Cybersecurity and Disclosures

    Cybersecurity and Disclosures

    The United States Securities and Exchange Commission (SEC or Commission) recently issued two critical Consent Orders, First American Title [2] and Pearson, [3] both articulating the need for timely, fulsome, and accurate disclosures to the market when a data breach occurs...

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    1. As a result of First American's deficient disclosure controls, senior management was completely unaware of this vulnerability and the company's failure to remediate it.
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