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ARTICLE · 04 NOVEMBER 2021

Ensure Disclosure Controls And Procedures Address Cybersecurity

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The SEC's order charges First American with violating Rule 13a-15(a) of the Securities Exchange Act of 1934.

United StatesFinance and Banking
Peter Fetzer
Peter Fetzer
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On June 15, 2021, the Securities and Exchange Commission (SEC) announced settled charges against real estate settlement services company First American Financial Corporation for disclosure controls and procedures violations related to a cybersecurity vulnerability that exposed sensitive customer information.  The SEC's order charges First American with violating Rule 13a-15(a) of the Securities Exchange Act of 1934.  Without admitting or denying the SEC's findings, First American agreed to a cease-and-desist order and to pay a $487,616 penalty.

Why We are Sending this Alert:  To remind issuers that they should ensure that their disclosure controls and procedures address cybersecurity and include elements intended to ensure that there is an analysis of potential disclosure obligations arising from cyberattacks and security breaches.

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