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Data Security Risk Alert

Goodwin

SEC EXAMS Division Issues Reg. S-ID Risk Alert

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The SEC Division of Examinations recently published a risk alert summarizing observations from exams of registered investment advisers and broker-dealers related to compliance with Reg. S-ID, which is generally designed to...more

Moore & Van Allen PLLC

SEC Announces Exam Priorities for 2022

On March 30, 2022, the U.S. Securities and Exchange Commission’s (“SEC”) Division of Examinations released its exam priorities for fiscal year 2022 (the “2022 Priorities”). As in years past, these exam priorities naturally...more

Dechert LLP

OCIE Issues Cybersecurity Risk Alert on the Risk of Credential Stuffing Attacks

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The Risk Alert makes clear that OCIE has observed an increase in the frequency of credential stuffing attacks against Registrants, including some successful credential stuffing attacks that resulted in the loss of customer...more

Proskauer - The Capital Commitment

Privacy in the Time of Pandemic: COVID-19 Provides Opportunity to Revisit Regulation S-P Privacy Policies

With more people working remotely than ever before in light of COVID-19, firms in the private equity and hedge fund space should review their Regulation S-P privacy and information-safeguarding policies to ensure they are...more

Pillsbury Winthrop Shaw Pittman LLP

Despite COVID-19 Challenges, No Extension of Form CRS Compliance Date for Investment Advisers

On April 7, 2020, the staff of the Office of Compliance Inspections and Examinations (OCIE) issued a risk alert (Alert) informing investment advisory firms of the potential areas of focus for Form CRS-related examinations. In...more

Proskauer Rose LLP

OCIE Publishes Cybersecurity and Resiliency Observations

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Background - On January 27, 2020, the U.S. Securities and Exchange Commission's Office of Compliance Inspections and Examinations ("OCIE") published its Cybersecurity and Resiliency Observations. Cybersecurity and data...more

Robinson+Cole Data Privacy + Security Insider

New York DFS Issues Risk Alert Concerning Possible Iran Cyber-Attacks

In view of Iran’s vows to retaliate against the United States for the death of Quassem Soleimani, the NYDFS has issued an industry letter  to all regulated entities regarding the need for heightened cybersecurity precautions....more

Sheppard Mullin Richter & Hampton LLP

SEC Issues Alert On Outsourcing and Data Security

The SEC recently issued a risk alert warning about using vendors and cloud-based platforms. Many broker dealers and investment advisors are turning to these third parties to store customer data. In its alert, the SEC’s Office...more

Skadden, Arps, Slate, Meagher & Flom LLP

Privacy & Cybersecurity Update - May 2019

In this month's edition of our Privacy & Cybersecurity Update, we examine expanded data breach notification laws in New Jersey and Washington state, as well as the SEC's risk alert regarding cloud-based storage solutions. We...more

Akin Gump Strauss Hauer & Feld LLP

SEC OCIE Issues Guidance on Advisors’ and Broker-Dealers’ Cloud-Based and Other Network Storage of Customer Data

• On May 23, 2019, the Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert describing its observations in past examinations of weaknesses and best practices...more

Faegre Drinker Biddle & Reath LLP

U.S. Securities and Exchange Commission Issues Risk Alert Regarding Safeguarding Customer Records and Information Stored on...

On May 23, 2019, the United States Securities and Exchange Commission (“SEC”)’s Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert entitled “Safeguarding Customer Records and Information in Network...more

Baker Donelson

SEC Issues Risk Alert on Regulation S-P

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It should not be surprising to anyone that cybersecurity and data protection remain top priorities for regulators of the financial services industry. Indeed, cybersecurity has been regularly identified as a key priority by...more

Sheppard Mullin Richter & Hampton LLP

SEC Issues Risk Alert on Customer Privacy Safeguards

Earlier this month, the Securities and Exchange Commission (“SEC”) took a break from its recent focus on digital assets and the Best Interest fiduciary standard to publish a Risk Alert encouraging investment advisers and...more

Akin Gump Strauss Hauer & Feld LLP

SEC Warns Registered Firms about Client Privacy and Data Security

• The SEC released a Risk Alert summarizing key areas in which it continues to see compliance deficiencies related to Regulation S-P, the primary SEC rule regarding privacy notices and safeguard policies of investment...more

Patterson Belknap Webb & Tyler LLP

SEC Warns Advisers Over Privacy Compliance Issues

The Securities and Exchange Commission is warning investment firms to step up their game when it comes to following the agency’s privacy rules. In a Risk Alert issued by the Office of Compliance Inspections and Examinations...more

McGuireWoods LLP

SEC OCIE Highlights Potential Deficiencies in Firm Privacy Policies

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On April 16, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert highlighting Regulation S-P compliance deficiencies and issues it found in recent examinations of broker-dealers and...more

UB Greensfelder LLP

The SEC Released A Risk Alert On Reg S-P, a/k/a How To Avoid A $1 Million Penalty

UB Greensfelder LLP on

I am hardly saying that SEC Regulation S-P is the sexiest of regulations. I mean, has any customer is history actually read one of those exciting statement stuffers that discloses in some dense font a BD’s privacy policy?...more

BakerHostetler

SEC Updates Data Privacy and Cybersecurity Guidance for Registered Firms

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On April 16, 2019, the Office of Compliance Inspections and Examinations (OCIE) of the Securities and Exchange Commission (SEC) issued a risk alert, “Investment Adviser and Broker-Dealer Compliance Issues Relating to...more

Fox Rothschild LLP

OCIE Issues Risk Alert Regarding Compliance With Regulation S-P’s Notice And Safeguard Policy Requirements

Fox Rothschild LLP on

On April 16, the Securities and Exchange Commission (SEC)’s Office of Compliance Inspections and Examinations (OCIE) released a new Risk Alert that identifies common compliance issues facing investment advisers and...more

Alston & Bird

SEC Issues Risk Alert Noting Common Regulation S-P Compliance Issues

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The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) has issued a Risk Alert that provides an overview of the most common deficiencies or weaknesses in investment adviser and broker-dealer compliance with the...more

Jackson Lewis P.C.

SEC Issues Privacy And Data Security Risk Alert

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Following recent examinations of SEC-registered investment advisers and broker-dealers, the Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) published a privacy risk alert on...more

Dechert LLP

OCIE Publishes Risk Alert on the Use of Electronic Messaging by Investment Advisers and Employees

Dechert LLP on

The U.S. Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) issued a National Exam Program Risk Alert on December 14, 2018 concerning the use of electronic messaging by registered...more

Skadden, Arps, Slate, Meagher & Flom LLP

OCIE Releases Results of Cybersecurity Examination Initiative

On August 7, 2017, the Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission (SEC) released a summary of its observations (the report) from cybersecurity examinations of 75...more

BakerHostetler

SEC Cybersecurity Risk Alert Emphasizes Proactive Compliance and Ongoing Vigilance

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On August 7, 2017, the Securities and Exchange Commission (SEC) released its latest cybersecurity risk alert, detailing findings from the examination of 75 broker-dealers, investment advisers and investment companies carried...more

Patterson Belknap Webb & Tyler LLP

SEC Watch: “Observations” from SEC’s Cybersecurity 2 Initiative

Last week, the U.S. Securities and Exchange Commission’s (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”) released its “Observations from Cybersecurity Examinations” conducted pursuant to OCIE’s...more

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