SEC Enforcement Report Comes Down Hard on Advisers; Your Chance to Sound Off About the SEC’s Proposed Advertising & Cash Solicitation Rule Changes; Mutual Funds Placed on SEC’s Naughty List: Regulatory Update for December 2019

SEC Declares Victory for 2019 Despite all Obstacles: Division of Enforcement Publishes Annual Report for Fiscal Year 2019. Starting with the usual self-serving statements about the Commission’s success in punishing the bad guys and returned ill-gotten gains to harmed investors, the SEC’s Division of Enforcement proudly announced the issuance of its Annual Report for Fiscal Year 2019. The report highlights a wide range of enforcement cases, including corporate fraud, auditing failures, investment advisory issues, insider trading, and broker-dealer misconduct. In 2019, the SEC brought 862 enforcement actions, returned roughly $1.2 billion to harmed investors, received $4.3 billion in disgorgement and penalties, suspended 271 companies, and issued nearly 600 individual bars and suspensions. In 2018, the SEC brought 821 enforcement actions, returned $794 million to investors, received $3.945 billion in disgorgement and penalties, suspended 280 companies, and issued 550 individual bars and suspensions. In 2019, actions against investment advisers and investment companies held the top position with 35% of cases, a significant uptick from 22% in 2018. This increase is primarily attributable to the SEC’s Share Class Selection Disclosure Initiative. Contributed by Jaqueline M. Hummel, Partner and Managing Director.

California Has Bigger Fish to Fry with its new Consumer Privacy Act. California’s Consumer Privacy Act of 2018 (CCPA) goes into effect on January 1st, 2020 and while the scope and complexity of the Act far exceed this scope of this newsletter, here are a few facts:

  1. The CCPA applies to for-profit firms that are “doing business” in California and meet one of the three thresholds: (a) Generates annual gross revenue of greater than $25 million, (b) Receives or shares data of greater than 50,000 California residents annually, or (c) Derives at least 50 percent of its annual revenue by selling the personal information of CA residents. These criteria apply whether or not the firm has a physical location in the state, but certain types of firms, such as financial institutions already covered by Gramm-Leach-Bliley, are exempt. Conceptually, if an investment adviser collects personal information that is subject to Regulation S-P, then the CCPA does not apply to that information. The same is true for exempt reporting advisers since they are subject to the CFPB’s Regulation P. However, advisers can still get sued for data breaches if they have failed to implement reasonable security procedures to safeguard personal information.
  2. Amendments. Bills passed in September 2019 amended the CCPA and clarified several key aspects that should assist firms in preparing for compliance. Among these, the definition of “personal information” has been revised and relief made available to certain businesses.
  3. Important dates. The CCPA becomes effective January 1st, and the attorney general will begin enforcement no later than July 1, 2020. That said, in-scope firms should also note that the rule contains a look back provision under which consumers may request access to their personal information gathered by the firm for the prior twelve months. Contributed by Cari A. Hopfensperger, Senior Compliance Consultant.

New Hampshire to Terminate RIA and BD Firms for Late Renewals. The New Hampshire Bureau of Securities Regulation (“Bureau”), warned its registrants of a new policy that becomes effective for 2020 renewals. The Bureau eliminated the grace period once extended to broker-dealers and SEC- and state-registered investment advisers to renew their registrations. This year, if a firm fails to renew by December 31, 2019, its registration will be terminated, and it will no longer be eligible to conduct securities or investment advisory business in New Hampshire. Firms that violate this policy may be subject to enforcement action. New Hampshire’s new approach is similar to Texas, where Firms and their registered individuals will already go into “Fail to Renew” status on January 1st if fees have not been paid. Keep in mind, Web CRD and IARD will shut down for year-end at 6:00 p.m. Eastern Time on December 26th. Don’t delay! Contributed by Rochelle A. Truzzi, Senior Compliance Consultant.

2020 CRD/ IARD Renewal Programs. Please review the corresponding 2020 Renewal Calendar (Broker-Dealer or RIA/IARD), noting the following important dates in December:

  • 12/16/2019 – DEADLINE for receipt of payment in full of Preliminary Statements;
  • 12/26/2019 – LAST DAY to submit Forms U4, U5, BD, and BDW for the year.

Additional details, including payment methods, can be found in FINRA Notice 19-35 for Broker-Dealers and on the IARD Renewal Program webpage for Investment Advisers. Hardin recommends that funds be remitted through E-Bill, in advance of the deadlines, to allow sufficient time for processing. Contributed by Rochelle A. Truzzi, Senior Compliance Consultant.

For Investment Advisers: SEC Actions

Speak Now or Forever Hold Your Peace! It’s Your Chance to Comment on the SEC’s Advertising and Cash Solicitation Rule Change. It’s taken more than 60 years, but the SEC has finally proposed changes to the Advertising Rule (Rule 206(4)-1), and the Cash Solicitation Rule (Rule 206(4)-3). The scope of the proposed amendments to the advertising rule is vast, and the SEC seems hungry for industry feedback, asking readers to weigh in on more than 400 different questions on everything from testimonials, past specific recommendations, and case studies, to performance calculations and portability. Significantly, the proposed release redefines “advertising” more broadly than the current rule, employs a largely principles-based approach, and requires advisers to appoint a person to review and pre-approve most advertising. Now is the time to have your voice heard! Advisers can quickly provide comments by using the SEC’s comment form or sending an email to and include File Number S7-21-19 on the subject line. Check out the Worth Reading section below for more resources on the proposal.

The SEC is expanding the term “compensation” under the proposed amendments to the Cash Solicitation Rule to include all forms of compensation, not just cash. The proposal would also cover solicitation of investors in private funds, and include de minimis exemptions for solicitors (less than $100 in any 12-month period). Contributed by Jaqueline M. Hummel, Partner and Managing Director.

Reminder: GIPS 2020. The CFA Institute adopted the 2020 GIPS Standards (“GIPS 2020”) on June 30, 2019, and, for those firms claiming compliance with the voluntary performance presentation standards, the big day is nearly here as GIPS 2020 standards become effective on January 1, 2020. Don’t panic, though; firms have another year to update their GIPS presentations (i.e., “GIPS Composite Reports”) to comply with the new disclosure requirements. While many of the changes in GIPS 2020 were designed to attract new types of firms to pursue GIPS compliance, firms that already claim compliance should also be aware of how the new standards impact their current policies and procedures. For example, firms interested in presenting carve-out performance or private fund managers interested in presenting fund vs. composite performance may appreciate new flexibility in the revised standards. Looking for details? The CFA Institute has grouped its materials related to GIPS 2020 on a dedicated webpage and summarized the top 10 FAQs raised by firms, service providers, and others in the industry during the open comment period. Check out our updates from October 2018 and July 2019. Contributed by Cari A. Hopfensperger, Senior Compliance Consultant.

For Broker-Dealers: SEC and FINRA Actions

Form CRS Template. Coming soon for RIAs and Broker-Dealers! In the meantime, bookmark Hardin’s dedicated webpage for updates on all things related to Form CRS. Contributed by Rochelle A. Truzzi, Senior Compliance Consultant.

SEC Extends SIFMA Temporary No-Action Letter Until July 3, 2023. During the extended period, broker-dealers may continue to receive payments for research services provided to investment managers subject to MiFID II that would otherwise constitute investment advice under section 202(a)(11) of the Advisers Act. Contributed by Rochelle A. Truzzi, Senior Compliance Consultant.

SEC Dips its Toe into the Water with Blockchain. The SEC granted Paxos Trust Company, LLC (“Paxos Trust”) no-action relief allowing it to launch a blockchain-based settlement platform for U.S. listed equities. For the first time in decades there will be an option for settling U.S. listed equities other than the traditional settlement process. Blockchain, which is more closely associated with the system powering Bitcoin, is a shared database maintained by a network of computers. The Paxos Trust platform will not be live until one of its early adopters has received approval from the SEC to settle with Paxos. To get to this point, Paxos has been working on the service for the past two years. The company approached the SEC eighteen months ago and submitted its no-action request about six months ago. The platform will allow two parties to settle securities trades directly with each other and, over the long-term, is intended to modernize the settlement process. Contributed by Doug MacKinnon, Senior Compliance Consultant.

For Mutual Fund Managers: SEC Actions

Investment Companies Placed on the SEC’s Naughty List. OCIE issued a Risk Alert discussing the most often cited deficiencies and weaknesses it observed during hundreds of fund examinations over a two-year period. Here are some of the highlights:

Violations of Rule 38a-1 of the Investment Company Act, the Fund Compliance Rule:

  • Funds failed to customize their compliance programs to address risks specific to the fund’s activities.
  • Funds failed to follow or enforce their policies and procedures, especially with respect to valuation.
  • Funds conducted inadequate service provider oversight.
  • Funds failed to conduct annual reviews of their compliance programs, or the reviews were inadequate.

Fund disclosures to shareholders were incomplete or misleading as compared to the fund’s actual activities.

The Section 15(c) Process for approving investment advisory contracts was flawed:

  • Boards failed to request or consider reasonably necessary information, such as the profitability of the fund to the adviser, economies of scale, or peer group comparisons.
  • Shareholder reports contained inadequate discussion of the basis for board approval of the advisory contract.

Fund Code of Ethics Rule:

  • Funds did not implement a code of ethics.
  • Funds failed to follow or enforce their existing code of ethics.
  • Funds did not comply with the code of ethics approval and reporting process.

Money Market Funds:

  • Fund staff did not maintain credit files with documentation to support a determination that certain securities presented minimal risk and qualified as “eligible securities.”
  • Stress test results presented to fund boards did not include the required summary of significant assumptions.
  • Funds did not implement or adopt policies and procedures related to Rule 2a-7 compliance.
  • Funds failed to post accurate or all required information, as required by Rule 2a-7, on fund websites, and required legends were missing from advertising materials.

Target Date Funds

  • Funds included incomplete or potentially misleading disclosures in prospectuses and advertisements.
  • The funds were missing or had incomplete policies and procedures.

 Doug MacKinnon, Senior Compliance Consultant.

Small Fund Family Liquidity Risk Management Programs. Advisers to small mutual fund families (those with assets less than $1 billion) likely need no reminder of the final, December 1, 2019, compliance date of Rule 22e-4 under the Investment Company Act of 1940 (the “Liquidity Rule”) and the related requirements to implement a Liquidity Risk Management Program. With the arrival of this final compliance date, advisers to small fund families should have (1) obtained Board approval of the fund’s Liquidity Risk Management Program, (2) decided upon a classification process by which the fund’s investments are placed into one of four defined liquidity buckets (including whether the classification of investments will be performed by the adviser or a third party vendor, as well as inputs and assumptions relevant to that calculation, such as a Reasonably Anticipated Trade Size (“RATS”) and a material price impact (“MPI”), and (3) established the fund’s Highly Liquid Investment Minimum (“HLIM”) and related shortfall procedures OR determined that the fund is a primarily highly liquid fund. Small fund families (with a December fiscal year-end) may find some relief in the reminder that their funds’ initial Form N-PORT filings are not due until May 2020, for the fiscal quarter ended March 31st. Check out our prior blog post: SEC Requires Mutual Funds to Adopt Liquidity Risk Management Programs. Contributed by Cari A. Hopfensperger, Senior Compliance Consultant.

For Hedge Fund Managers: NFA Actions

NFA Requires Firms to Appoint Swaps Proficiency Requirement Administrator. About the new swaps proficiency requirements becoming effective January 1, 2020, NFA Members with Associated Persons who are required to take the NFA’s Swaps Proficiency Requirements must also designate one or more Swaps Proficiency Requirements Administrators (“SPR Admins”) to coordinate enrollment and track progress. The SPR Admin must also be an ORS Security Manager. To assist affected firms, NFA is publishing a series of webinars designed for SPR Admins. The last available webinar will be on December 10th and will cover the technical aspects of administering the program. The NFA has stated that recordings will also be made available. Register for the webinar: NFA SPR Admin Webinar and see instructions on how to register SPR Admins: SPR Admin Form Instructions. Contributed by Mark L. Silvester, Compliance Associate.

Amendments to NFA Promotional Material Rules and Interpretive Notices. On January 1, 2020, amendments clarifying the applicability of NFA Compliance Rules 2-29 and 2-36 and related Interpretive Notices become effective. These amendments are intended to better reflect current technology and business practices and address the use of hypothetical performance in promotional material by CPO members operating under a Rule 4.7 exemption. Rule 2-36 was also amended to specify that Forex Dealer Members and their associates must comply with specific provisions of Rule 2-29. Contributed by Mark L. Silvester, Compliance Associate.

Photo Credits: Photo by Lauren Mancke on Unsplash

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JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
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Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
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  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

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Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at:

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