News & Analysis as of

Regulation S-P Risk Assessment

Jackson Lewis P.C.

The Broadening Data Security Mandate: SEC Incident Response Plan and Data Breach Notification Requirements

Jackson Lewis P.C. on

Virtually all organizations have an obligation to safeguard their personal data against unauthorized access or use, and, in some instances, to notify affected individuals in the event such access or use occurs. Those...more

Foley & Lardner LLP

SEC Tightens Cybersecurity Requirements with Regulation S-P Amendments

Foley & Lardner LLP on

Share on Twitter Print Share by Email Share Back to top “The basic idea for covered firms is if you’ve got a breach, then you’ve got to notify. That’s good for investors.” Those were among the remarks that U.S. Securities and...more

Foley Hoag LLP - Security, Privacy and the...

SEC Revamps and Enhances Data Protections with Amendments to Regulation S-P

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

Vinson & Elkins LLP

Cyber(in)security: New York Levies Fine for Failure to Implement Written Policies

Vinson & Elkins LLP on

On November 27, 2023, the New York State Department of Financial Services (“DFS”) and First American Title Insurance Company (“First American”) entered into a consent order1 that resolved litigation over First American’s...more

Lowenstein Sandler LLP

Investment Advisers, Broker-Dealers, and Other Financial Industry Participants Take Note: SEC Demonstrates Commitment to...

Lowenstein Sandler LLP on

On March 15, 2023, the Securities and Exchange Commission (“SEC”) issued three releases proposing (i) amendments to Regulation S-P (“Regulation S-P Proposal”)1, (ii) amendments to Regulation SCI (“Regulation SCI Proposal”)2,...more

Jones Day

SEC Releases Cybersecurity Observations and Guidance - The SEC's Office of Compliance Inspections and Examinations ("OCIE")...

Jones Day on

On January 27, 2020, OCIE issued a report detailing cybersecurity and resiliency observations the staff made after "thousands of examinations of broker-dealers, investment advisers, clearing agencies, national securities...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

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

Dechert LLP

The Good and the Bad from OCIE’s Cyber Examinations and What Firms Should Do Next

Dechert LLP on

The Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission (SEC) released a National Examination Program Risk Alert (Risk Alert) on August 7, 2017 regarding observations from...more

Carlton Fields

Cybersecurity Still Top FINRA Operational Risk

Carlton Fields on

On January 4, the Financial Industry Regulatory Authority (FINRA) published its annual Regulatory and Examination Priorities Letter providing firms with information about areas FINRA plans to review in 2017 as well as...more

NAVEX

Reports Reveal Four Cyber Security Trends—and the Need for Better Cyber Security Training & Awareness

NAVEX on

As cyber security issues continue to escalate and evolve, compliance officers have more opportunities to better protect and defend their organizations from cyber risk. One of compliance officers’ responsibilities is to stay...more

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

Foley & Lardner LLP on

Non-Enforcement Cybersecurity Is At the Top of SEC Examination Concerns In a recent SEC “risk alert” for registered broker-dealers and investment advisers, the SEC’s Office of Compliance Inspections and Examinations (OCIE)...more

Perkins Coie

SEC’s Increased Cybersecurity Enforcement and How to Reduce Your Risks

Perkins Coie on

The SEC announced last week that an investment adviser had agreed to settle charges that it failed to take required steps to protect against and respond effectively to a cybersecurity breach. The action comes on the heels of...more

BakerHostetler

The SEC OCIE Announces Increased Scrutiny of Broker-Dealers’ and Investment Advisers’ Cybersecurity Programs

BakerHostetler on

On September 15, 2015, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) issued a National Exam Program Risk Alert (2015 Risk Alert) to provide broker-dealers and investment...more

Katten Muchin Rosenman LLP

Cyber-Attacks: Threats, Regulatory Reaction and Practical Proactive Measures to Help Avoid Risks

I. Cybersecurity; Its Importance and Relevance – How We Got to Where We Are Today - In the past few months, the White House, Home Depot, JP Morgan, Hard Rock Hotels, Tesla, the St. Louis Federal Reserve, the Internal...more

BakerHostetler

Broker-Dealers and Investment Advisers Now Targeted by Both Cyber Intruders and SEC Cybersecurity Examiners

BakerHostetler on

Cybersecurity has increasingly become a critical issue for all types of businesses, few more so than broker-dealers, investment advisers and others in the financial sector. The cyber threat is much broader than customer data...more

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