Skip to content

Menu

LexBlog, Inc. logo
NetworkSub-MenuBrowse by SubjectBrowse by PublisherJoin the NetworkGet StartedSubscribeSupportContact
Search
Close

The SEC’s SolarWinds Enforcement FAQs

By Jason Day & Lou Mejia on June 25, 2021
Email this postTweet this postLike this postShare this post on LinkedIn

Earlier this week, we blogged about the SEC’s SolarWinds enforcement inquiries. This morning, the SEC issued guidance in the form of 19 FAQs for responding to the voluntary request for information relating to a SolarWinds inquiry.

For most companies, the important points are:

  • The SEC identified the specific compromised versions of the software: Version 2020.2 (with no hotfix); Orion Platform software version 2020.2 HF 1; and Orion Platform software version 2019.4 HF 5.
  • If a recipient’s responses to Items 1(a) and 1(b) do not include any of those versions of the Orion Platform software, then it does not need to respond to Request Nos. 2-5 of Attachment A.
  • The SEC repeated its position that Question 5, which seeks information about “other compromises” includes non-material events. Our prior guidance regarding how to respond to question 5 remains unchanged.

 

Photo of Jason Day Jason Day

Jason Day is the firmwide chair of the Corporate practice and a member of the firm’s Executive Committee. Jason serves as a trusted advisor to public companies on their most sensitive securities and corporate governance matters. He regularly counsels public company boards of…

Jason Day is the firmwide chair of the Corporate practice and a member of the firm’s Executive Committee. Jason serves as a trusted advisor to public companies on their most sensitive securities and corporate governance matters. He regularly counsels public company boards of directors and management on SEC disclosure obligations, fiduciary duties, internal investigations, proxy advisory firm standards and stockholder activism matters.

Jason has represented issuers and underwriters in dozens of capital markets offerings, including underwritten equity and debt offerings, initial public offerings, Rule 144A offerings and convertible note offerings, among others. He also counsels companies and their boards on public company change in control transactions, including mergers, tender offers, and SPAC transactions.

Read more about Jason DayEmail
Show more Show less
  • Posted in:
    Banking, Finance and Securities, Privacy and Cybersecurity
  • Blog:
    Public Chatter
  • Organization:
    Perkins Coie LLP
  • Article: View Original Source

Call us at 1-800-913-0988 or email sales@lexblog.com.

Facebook LinkedIn Twitter RSS
The Library at LexBlog
  • About LexBlog
  • The Field We Built
  • Library at LexBlog
  • Our Beliefs
  • Our Team
  • Contact LexBlog
  • Disclaimer
  • Editorial Policy
  • Terms of Service
  • Get Started
  • Publishing Solutions
  • Compass
  • Submit a Request
  • Support Center
  • System Status
Copyright © 2026, LexBlog, Inc. All Rights Reserved.
Law blog design & platform by LexBlog LexBlog Logo