During the course of any lending transaction, lenders will conduct a due diligence review of the borrower, including reviewing any relevant “know-your-customer” information. In the context of a fund finance transaction, this...more
10/10/2024
/ Borrowers ,
California Consumer Privacy Act (CCPA) ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Due Diligence ,
EU ,
Financial Institutions ,
Firewalls ,
General Data Protection Regulation (GDPR) ,
Investors ,
Lenders ,
Multi-Factor Authentication ,
SaaS
A global technology outage linked to the cybersecurity firm CrowdStrike crashed Microsoft apps and triggered major disruptions across the asset management sector, along with other global industries. Private fund managers...more
Last week, the Securities and Exchange Commission imposed expanded privacy and cybersecurity obligations on fund managers and sponsors registered with the SEC as investment advisers. While many registered investment advisers...more
5/21/2024
/ Breach Notification Rule ,
Customer Information ,
Cybersecurity ,
Fund Managers ,
Incident Response Plans ,
Investment Adviser ,
Notice Requirements ,
Policies and Procedures ,
Privacy Laws ,
Private Funds ,
Recordkeeping Requirements ,
Regulation S-P ,
Securities and Exchange Commission (SEC) ,
Sponsors
Investment Advisers: Assessing Risks, Scoping Examinations, and Requesting Documents*
I. Introduction -
The SEC-registered investment adviser (“adviser”) population is large and diverse, ranging from global asset managers...more
9/12/2023
/ Audits ,
Brokerage Accounts ,
Business Operations ,
Compliance ,
Cybersecurity ,
Disclosure Requirements ,
Ethics ,
Financial Records ,
Insider Trading ,
Internal Controls ,
Investment Adviser ,
Marketing ,
Policies and Procedures ,
Risk Alert ,
Risk Management ,
Securities ,
Securities and Exchange Commission (SEC) ,
Trading Platforms ,
Valuation
On Tuesday, February 7, the Division of Examinations of the U.S. Securities and Exchange Commission released its 2023 Examination Priorities. Private fund sponsors and managers should pay attention to the Priorities for two...more
On August 30, 2021, the Securities and Exchange Commission announced three enforcement actions against registered investment advisers for alleged cybersecurity failures involving cloud-based email systems. All three actions...more