In recent years, the SEC has been focused on cybersecurity. It has issued risk alerts, conducted examinations and provided guidance about what the agency sees as widespread weaknesses in many policies and procedures to...more
9/28/2015
/ Broker-Dealer ,
Cease and Desist Orders ,
Civil Monetary Penalty ,
Cyber Attacks ,
Cyber Incident Reporting ,
Cyber Threats ,
Cybersecurity ,
Data Breach ,
Data Privacy ,
Data Protection ,
Data Security ,
Enforcement Actions ,
Hackers ,
OCIE ,
Personally Identifiable Information ,
Policies and Procedures ,
Registered Investment Advisors ,
Regulation S-P ,
Risk Alert ,
Securities and Exchange Commission (SEC) ,
Security Risk Assessments
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
For those clients that received extensions on the filing deadline for their BE-10 surveys, they are reminded that the August 31, 2015 deadline is approaching. The BE-10 is the five year benchmark survey of United States...more
On July 30, 2015, the European Securities and Markets Authority (ESMA) released its advice to the European Parliament, Council of the European Union and the European Commission on the application of the passport to non-EU...more
8/5/2015
/ AIF ,
AIFM ,
Alternative Investment Fund Managers Directive (AIFMD) ,
EU ,
EU Council of Ministers ,
European Commission ,
European Securities and Markets Authority (ESMA) ,
Hong Kong ,
Investor Protection ,
Investors ,
Marketing ,
Singapore ,
Switzerland
On June 8, 2015, a joint letter was sent to the U.S. Department of Commerce Secretary Penny Pritzker raising broad concerns with the Form BE-10 survey, including requirements for consolidation, burden of reporting, need for...more
The BEA has posted on its website that the filing deadline for all “new filers” for the BE-10 (which is the five year benchmark survey of United States direct investment abroad) has been extended to June 30, 2015. A new filer...more
Bureau of Economic Analysis Forms BE-13 and BE-10 -
Companies should take note that the U.S. Bureau of Economic Analysis (BEA) has announced two updated filing requirements relating to cross-border investment: BE-13...more
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
As a reminder, the Identity Theft Red Flags Rules jointly adopted by the SEC and CFTC, which took effect on May 20, 2013, have an upcoming compliance date of November 20, 2013. Under these rules, certain SEC and...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