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Corporate Governance Office of Compliance Inspections and Examinations

Proskauer - The Capital Commitment

ESG-Focused Fund Strategies Face SEC Scrutiny on Disclosures and Internal Procedures

As investors drive demand for investment products focused on environmental, social and governance (ESG) factors, fund managers have increasingly offered ESG-focused or “sustainable investing” funds. However, a recent speech...more

NAVEX

3 Coronavirus Compliance Tips From the SEC

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The coronavirus crisis is far from over, and compliance professionals still need every scrap of guidance that regulators can provide about how to run compliance programs in these difficult times. So when the Securities and...more

WilmerHale

SEC Guidance for Private Fund Advisers

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On June 23, 2020, the US Securities and Exchange Commission (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a risk alert (Risk Alert) describing common deficiencies and compliance issues for...more

Stoel Rives LLP

In Case You Missed It - Interesting Items for Corporate Counsel - February 2020

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The SEC proposed updates to Regulation S-K to modernize, simplify and enhance financial disclosures, here. The SEC’s press release, here, summarizes the changes as well as any law firm memo (but see here and here if you don’t...more

Vedder Price

OCIE Publishes Cybersecurity and Resiliency Observations

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On January 27, 2020, the SEC’s Office of Compliance Inspections and Examinations (OCIE) published observations from its examinations of regulated entities, including funds and investment advisers, to assist those entities in...more

Dechert LLP

2020/02/13 OCIE Releases 2020 Cybersecurity Observations

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The Office of Compliance Inspections and Examinations of the Securities and Exchange Commission released cybersecurity and resiliency-related examination observations on January 27, 2020, based on “thousands of examinations...more

Kramer Levin Naftalis & Frankel LLP

Cybersecurity: the SEC Provides Guidance on Well-Known and Emerging Best Practices

At the end of January, the U.S. Securities and Exchange’s Office of Compliance Inspections and Examinations (OCIE) released its “Observations on Cybersecurity and Resiliency Practices” (Observations)....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

Carlton Fields

OCIE Risk Alert Highlights Compliance Program Catch-22

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A risk alert issued on November 7, 2019, by the SEC’s Office of Compliance Inspections and Examinations underscores a continuing dilemma faced by SEC-regulated entities....more

Hogan Lovells

SEC Releases Cybersecurity and Resiliency Observations: A Potentially Useful Guide for Businesses

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In today’s connected world, businesses face constant pressure to improve their cybersecurity practices and to confirm that they are meeting industry standards. To continue helping businesses achieve those goals, the SEC...more

Dorsey & Whitney LLP

Cybersecurity: Key Considerations Developed by OCIE

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The SEC’s Office of Compliance Inspections and Examinations published a series of observations gleaned from thousands of exams over a period of years. While OCIE’s charge is the inspection of certain SEC registrants the...more

Vedder Price

OCIE Releases Risk Alert Summarizing Observations from Fund Exams and Recent Initiatives

Vedder Price on

On November 7, 2019, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a risk alert outlining its top compliance observations from examinations of nearly 300 registered funds conducted over a two-year...more

Dorsey & Whitney LLP

SEC Publishes Risk Alert with Observations from Examinations of Mutual Funds, Money Market Funds, and Target Date Funds

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On November 7, 2019, the SEC’s Office of Compliance Inspections and Examinations (OCIE) published a Risk Alert highlighting the most often cited deficiencies and weaknesses observed in recent examinations of registered...more

Morrison & Foerster LLP

SEC Is Ready To Execute Its 2019 Examination Priorities

The U.S. Securities and Exchange Commission’s Office of Compliance Inspections and Examinations published its 2019 examination priorities on Dec. 20, 2018. Since this occurred just prior to the implementation of a partial...more

Akin Gump Strauss Hauer & Feld LLP

Top 10 Topics for Directors in 2018

EXECUTIVE SUMMARY - 1. Cybersecurity threats. Cybersecurity preparedness is essential in 2018 as the risk of, and associated adverse impact of, breaches continue to rise. The past year redefined the upward bounds of the...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

Dickinson Wright

Analysis: Cyber-Monitoring: The Next Frontier

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Cybersecurity is “hot” and will stay “hot” for corporations, executives, regulators, law enforcement and legislators. Rarely is there a corporate compliance discussion in 2017 where cyber isn’t “the” topic or a material part...more

Fox Rothschild LLP

SEC’s Exam Deficiencies

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The SEC recently released its findings relating to exams of investment advisers. In particular, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) found weak compliance programs; insufficient or late...more

Proskauer on Privacy

SEC Cybersecurity Update

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Results from the SEC’s First Round of Cybersecurity Examinations - On February 3, 2015, the OCIE published a risk alert summarizing its findings from its examinations of over 100 registered investment advisers and...more

Snell & Wilmer

SEC Announces Second Wave of Cyber Exams of Broker Dealers and Advisors – Is Your Firm Ready?

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In April 2014, the Securities and Exchange Commission’s (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert announcing its first cybersecurity sweep initiative. Pursuant to that initiative,...more

Morgan Lewis

Proactive Approach To Cybersecurity: Recent SEC guidance and enforcement actions suggest that reactive firms may be in the SEC’s...

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In an environment where even the largest and most powerful corporations have fallen victim to data breaches, it can be challenging to fathom how to protect against the sophisticated and ever-evolving threat of cyber attacks....more

Foley & Lardner LLP

SEC Brings First Cybersecurity Enforcement Proceeding in Wake of Risk Alert

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Highlights Areas of High Risk and Examination Priorities for Financial Industry Firms - On September 15, the U.S. Securities and Exchange Commission’s (SEC’s) Office of Compliance, Inspections and Examinations (OCIE),...more

Manatt, Phelps & Phillips, LLP

SEC Ramps up Cybersecurity Scrutiny With Examination Priorities and an Enforcement Action

Why it matters - Signaling that it will continue to increase its scrutiny of firms' cybersecurity readiness, the Office of Compliance, Inspections and Examinations of the Securities and Exchange Commission (SEC) issued a...more

Burr & Forman

TN Ethics Opinion Approves Lawyers’ Cloud Storage of Client Data

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Tennessee has joined other states in formally approving lawyers’ cloud-storage of client-confidential data. The Board of Professional Responsibility (“BOPR”) held that lawyers ethically may use cloud storage for...more

Locke Lord LLP

New Round of SEC Cybersecurity Examinations of Financial Service Firms and Their Cyber Controls

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The Office of Compliance Inspections and Examinations (the OCIE) has just published a new Risk Alert on cyber risks and precautions identifying specific areas it will be focusing on during the second round of examinations of...more

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