Form SHL is a five-year mandatory benchmark survey filing commissioned by the Department of the Treasury and administered by the Federal Reserve Bank of New York (“FRBNY”) applicable to all U.S.-resident issuers with foreign...more
8/13/2024
/ Deadlines ,
Filing Requirements ,
Foreign Investment ,
FRBNY ,
Fund Managers ,
Investment Adviser ,
Investment Management ,
Reporting Requirements ,
Securities ,
Securities and Exchange Commission (SEC) ,
TIC-SHL ,
U.S. Treasury
The Securities and Exchange Commission (“SEC”) has announced the adoption of amendments to Regulation S-P (“Amendments”) to modernize and enhance the rules that govern the treatment of consumers’ nonpublic personal...more
5/30/2024
/ Broker-Dealer ,
Customer Information ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Data Security ,
Enforcement Actions ,
Incident Response Plans ,
Investment Adviser ,
Notice Requirements ,
Personally Identifiable Information ,
Policies and Procedures ,
Regulation S-P ,
Regulatory Requirements ,
Reporting Requirements ,
Risk Assessment ,
Securities and Exchange Commission (SEC)
As you may already be aware, the CCPA goes into effect on January 1, 2020. California’s Attorney General has issued draft regulations under the CCPA and final regulations are expected to be issued shortly. Below are some...more
Investment advisers and managers of private investment funds organized in the Cayman Islands should take note that on September 30, 2019, the Data Protection Law, 2017 (the "DPL"), is set to come into effect....more
Investment advisers, hedge and private fund managers and U.S.-resident entities should review whether they have any filing obligations under Treasury International Capital (“TIC”) Benchmark Form SHL (“Form SHL”). Form SHL is...more
Further to our recent Foley Adviser, the Cayman Islands Monetary Authority (CIMA) has clarified today that the deadline for the appointment by a Cayman unregulated fund of an Anti-Money Laundering Compliance Officer (AMLCO),...more
Last week, the Securities and Exchange Commission (SEC) announced settlements with 13 SEC registered investment advisers that had failed to file Form PF over multiple year periods....more
As many of you may already be aware, the European GDPR goes into effect during May 2018. Below are some frequently asked questions and answers about GDPR as a short guide to assist investment advisers and private fund...more
As many of you may already be aware, the European GDPR goes into effect during May 2018. Below are some frequently asked questions and answers about GDPR as a short guide to assist investment advisers and private fund...more
Investment advisers are reminded to review their filing obligations under the TIC Form SHC as reporting on this 5-year benchmark survey is due on March 3, 2017.
The survey collects information on holdings by U.S....more
The Securities and Exchange Commission (“SEC”) has recently proposed a new rule that would require SEC-registered investment advisers to adopt and implement written business continuity and transition plans (“BCP”) reasonably...more
On December 4, 2015, President Obama signed the Fixing America’s Surface Transportation Act (the ‘‘FAST Act’’) into law. Although the FAST Act’s main focus is on improving the country’s surface transportation infrastructure,...more
Now that the dust has settled a little on the BE-10 benchmark survey responses, U.S. financial service providers, including investment advisers, should take note that the U.S. Bureau of Economic Analysis (the “BEA”) has...more
9/30/2015
/ BE-180 ,
BEA ,
Benchmarks ,
Civil Monetary Penalty ,
Filing Deadlines ,
Financial Institutions ,
Form BE-10 ,
Form BE-13 ,
Investment Adviser ,
Offshore Funds ,
Reporting Requirements ,
Surveys ,
Time Extensions
Second Round of Cybersecurity Examinations to Begin -
On September 15, 2015, the Office of Compliance Inspections and Examinations (OCIE) of the Securities and Exchange Commission (SEC) issued a Risk Alert announcing a...more
9/21/2015
/ Broker-Dealer ,
Chief Information Security Officer (CISO) ,
Cyber Attacks ,
Cyber Incident Reporting ,
Cyber Insurance ,
Cyber Threats ,
Cybersecurity ,
Data Breach ,
Data Breach Plans ,
Data Privacy ,
Data Protection ,
Data Security ,
Investment Adviser ,
OCIE ,
Risk Alert ,
Securities and Exchange Commission (SEC) ,
Security Risk Assessments ,
Third-Party ,
Training
On April 28, 2015, the SEC’s Division of Investment Management (the “Division”) issued a Guidance Update regarding the SEC’s initiative to assess cybersecurity preparedness and threats in the securities industry, further...more
On June 3, 2014, the Massachusetts Securities Division released a survey to assess cybersecurity readiness and practices of Massachusetts-registered investment advisers....more
On April 15, 2014, the Office of Compliance Inspections and Examinations of the Securities and Exchange Commission (the “SEC”) issued a Risk Alert regarding the SEC’s initiative to assess cybersecurity preparedness and...more
In light of custody-related deficiencies identified by the Massachusetts Securities Division in recent examinations of Massachusetts-registered investment advisers, the Division released a Policy Statement on November 14,...more
Regulation S-ID -
On April 10, 2013, the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) jointly adopted identity theft red flags rules (the Rules) and corresponding...more