News & Analysis as of September 19, 2024

Cybersecurity › Industry Examinations

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Follow this channel for advisories on one of the biggest threats to businesses today. Read a morning brief of fresh guidance and commentary by leading lawyers on security, privacy, risk... more +

Follow this channel for advisories on one of the biggest threats to businesses today. Read a morning brief of fresh guidance and commentary by leading lawyers on security, privacy, risk management, global regulations, data protection, leaks, hacking, cyber insurance, compliance, HIPAA, and every other aspect of cybersecurity of import to corporate readers right now. less -

FINRA 2018 Priorities Letter Released

Burr & Forman on 1/9/2018

FINRA recently published its 2018 Annual Regulatory and Examination Priorities Letter, which identifies opportunities for firms to improve their compliance, supervisory and risk management policies or programs. ...more

SEC’s Latest Cybersecurity Risk Alert Identifies Elements of Robust Policies and Procedures

Dorsey & Whitney LLP on 8/15/2017

On August 7, 2017 the Securities and Exchange Committee (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”) released yet another cybersecurity Risk Alert entitled, “Observations from Cybersecurity...more

FINRA’s 2017 Regulatory & Exam Priorities

Burr & Forman on 1/6/2017

On January 4, new President and CEO Richard Cook issued FINRA’s Annual Regulatory and Examination Priorities Letter. This year’s list in summary is: New for 2017: Targeted electronic off-site reviews “on select...more

What’s Your Game Plan? Offensive or Defensive: Playing to Your Strengths [Expect Focus – October 2016]

Carlton Fields on 10/31/2016

- AXA Prevails at First Post-Jones v. Harris Excessive Fee Trial - Potential Secondary Effects of Regulatory Examinations: Evidentiary Issues and Preclusion in Parallel Litigation - On The Horizon: Global...more

Investment Management Update

Ballard Spahr LLP on 10/27/2016

Investment Adviser AXA Wins Excessive Fee Trial - A federal judge in New Jersey has ruled in favor of AXA Equitable Life Insurance Company (AXA Equitable) and its wholly owned subsidiary, AXA Equitable Funds Management...more

Member Of The Federal Reserve’s Board Of Governors Notes Benefits Of Consistent Cybersecurity Exam Approaches

King & Spalding on 7/21/2016

On June 24, 2016, in a response letter to Senator Dean Heller (R-NV), Daniel Tarullo, a member of the Board of Governors of the Federal Reserve System, highlighted the benefits of consistent cybersecurity supervisory...more

Recent Investment Management Developments - May 2016

Ballard Spahr LLP on 5/25/2016

Below is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry. ...more

SEC Cybersecurity Examinations and Enforcement: What Broker-Dealers and Investment Advisers Need to Know

Dechert LLP on 9/29/2015

The Securities and Exchange Commission’s (SEC or Commission) Office of Compliance Inspections and Examinations (OCIE) announced in a September 15, 2015 Risk Alert (2015 Risk Alert) that it will be conducting a second round of...more

SEC’s OCIE Issues a Second Cybersecurity Risk Alert

McGuireWoods LLP on 9/23/2015

On Sept. 15, 2015, the Securities Exchange Commission (SEC) Office of Compliance Inspections and Examinations (OCIE) published its second cybersecurity risk alert (the “2015 Risk Alert”). The 2015 Risk Alert is a follow up to...more

New Round of SEC Cybersecurity Examinations of Financial Service Firms and Their Cyber Controls

Locke Lord LLP on 9/23/2015

The Office of Compliance Inspections and Examinations (the OCIE) has just published a new Risk Alert on cyber risks and precautions identifying specific areas it will be focusing on during the second round of examinations of...more

SEC Says No More Mr. Nice Guy on Investment Adviser Cybersecurity

Brooks Pierce on 9/23/2015

Over the last couple years, the SEC’s cybersecurity bark has been worse than its bite. Its Office of Compliance, Inspections, and Examinations issued examination priorities in 2014. Commissioner Aguilar warned public...more

Bridging the Week - September 2015 #2

Katten Muchin Rosenman LLP on 9/22/2015

CFTC Says Virtual Currencies Are a “Commodity” Under Federal Law, Files Charges Against Coinflip for Operating an Unregistered Bitcoin Options Trading Platform - The Commodity Futures Trading Commission filed and...more

SEC OCIE Sharpens Focus on Cybersecurity

Akin Gump Strauss Hauer & Feld LLP on 9/21/2015

If you read one thing... - On September 15th, the SEC OCIE announced in a Risk Alert it will launch a second round of cybersecurity examinations of registered broker-dealers and investment advisers, which will be more...more

Recent Investment Management Developments - June 2015

Ballard Spahr LLP on 6/19/2015

In This Issue: - SEC Proposes Changes to Reporting and Disclosure Obligations for Investment Companies and Advisers - SEC Charges Hedge Fund Executives and External Auditor for Improper Disclosure of Expense...more

Going for Brokerages: FINRA and SEC Take Aim at Deficient Cyber Policies and Practices

Orrick, Herrington & Sutcliffe LLP on 6/18/2015

On Feb. 3, the Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) each released reports regarding cybersecurity issues for brokerage and advisory firms, both of which should be...more

Regulators Examining Cybersecurity Policies and Practices for the Insurance Industry

Robinson & Cole LLP on 4/24/2015

Shortly after the discovery of a cybersecurity breach at the health insurance company Anthem, Inc., the National Association of Insurance Commissioners (NAIC) called for a multi-state examination of Anthem’s cybersecurity...more

The Evolving U.S. Cybersecurity Landscape: What Firms Want to Know

Dechert LLP on 4/17/2015

Following a year of high-profile data breaches, the Securities and Exchange Commission (SEC) announced on January 13, 2015 that, for the second consecutive year, its Office of Compliance Inspections and Examinations (OCIE)...more

SEC Releases Results of Cybersecurity Exam Sweep

Brooks Pierce on 3/17/2015

We’re a bit behind on this, but better (a little bit) late than never. Last month the SEC’s Office of Compliance, Inspections and Examinations released the first results of its Cybersecurity Examination Initiative, announced...more

NYS Announces New Assessments Of Insurers’ Cybersecurity Practices

King & Spalding on 2/19/2015

On February 8, 2015, the New York State Department of Financial Services (“DFS”) issued a Report on Cyber Security in the Insurance Sector (the “Report”) and disclosed a series of steps it will be taking to bolster...more

SEC and FINRA Issue Cybersecurity Publications

Katten Muchin Rosenman LLP on 2/12/2015

On February 3, the Securities and Exchange Commission and Financial Industry Regulatory Authority issued separate publications on cybersecurity risk. The SEC’s risk alert provides summary observations from the SEC’s Office of...more

Bank Board Director Alert: Banking on Cybersecurity

Troutman Pepper on 2/9/2015

Prudential bank regulators and other supervisory authorities have put cybersecurity front and center in 2015 by issuing guidance that sets forth their expectations of improved cybersecurity and that incorporates cybersecurity...more

FINRA Cybersecurity Report Highlights Risks, Best Practices

Proskauer - Corporate Defense and Disputes on 2/9/2015

On February 3, 2015, the Financial Industry Regulatory Authority (“FINRA”) issued its Report on Cybersecurity Practices. Reinforcing FINRA’s emphasis on protecting investor information, the report discusses the results of a...more

SEC Releases Results of Financial Industry Examination Sweep Regarding Cybersecurity - The publications highlight the SEC’s...

King & Spalding on 2/9/2015

On February 3, 2015, the U.S. Securities and Exchange Commission (“SEC”) staff released two publications: the results of an examination sweep of 57 registered broker-dealers and 49 registered investment advisers, and guidance...more

OCC Report Highlights Wide Range of Potential Risks

Manatt, Phelps & Phillips, LLP on 1/20/2015

Why it matters - The OCC’s most recent report on current key risks should be read by all banks, regardless of size or regulator, as a road map in preparing for the next examination. Few banks would ever admit they may...more

New York Banks Face New Cybersecurity Exam Process

Manatt, Phelps & Phillips, LLP on 1/19/2015

Why it matters - Adding to the banks’ compliance obligations, effective immediately, banks chartered or licensed in New York will now face an updated cybersecurity examination process, Superintendent of the Department...more

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Cybersecurity › Industry Examinations

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