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Cybersecurity › Incident Response Plans › Investment Adviser

Follow this channel for advisories on one of the biggest threats to businesses today. Read a morning brief of fresh guidance and commentary by leading lawyers on security, privacy, risk... more +
Follow this channel for advisories on one of the biggest threats to businesses today. Read a morning brief of fresh guidance and commentary by leading lawyers on security, privacy, risk management, global regulations, data protection, leaks, hacking, cyber insurance, compliance, HIPAA, and every other aspect of cybersecurity of import to corporate readers right now.   less -
SEC Compliance Consultants, Inc. (SEC³)

Lessons From 2024: Tips for Private Fund Managers

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As we look back on the SEC’s actions in 2024, we wanted to share our thoughts on lessons learned that we believe will carry through to 2025....more

Snell & Wilmer

SEC Division of Examinations Priorities for 2025: Examinations Will Prioritize New Rules for Form PF and Regulation S-P, Fiduciary...

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On October 21, 2024, the Division of Examinations (the “Division”) of the U.S. Securities and Exchange Commission (the “SEC”) issued its annual examination priorities for fiscal year 2025. As with its 2024 examination...more

Carlton Fields

Going Up: SEC Cyber Incident Reporting - Regulation S-P Amendments Take It to Next Level

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On May 16, 2024, the SEC breathed new life into its decades-old Regulation S-P, which requires firms to adopt policies and procedures for the protection of customer information and records. The amended rule balloons the...more

Latham & Watkins LLP

SEC Imposes New Cybersecurity Requirements on BrokerDealers, Investment Companies, Registered Investment Advisers, and Transfer...

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Covered institutions will need to review their cybersecurity and incident response policies and procedures ahead of the applicable compliance deadline. The Securities and Exchange Commission (SEC) recently adopted...more

Paul Hastings LLP

SEC Adopts Amendments To Regulation S-P

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On May 15, 2024, the Securities and Exchange Commission (the “SEC”) adopted amendments to Regulation S-P. Originally passed in 2000, Regulation S-P regulates the treatment of non-public personal information of consumers by...more

SEC Compliance Consultants, Inc. (SEC³)

Regulatory Roundup for May 2024

SEC Compliance Consultants, Inc. (SEC³) on

SEC DROPS NEW REQUIREMENT FOR INCIDENT RESPONSE PROGRAMS, PROPOSAL FOR RIAS TO ADOPT CIP, SEC EXAMS SHARES MARKETING RULE FAILURES, RIA SLAMMED FOR FAILING TO RETAIN TEXTS, AND SEC WINS ON SHADOW TRADING THEORY - Welcome to...more

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

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

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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

Akin Gump Strauss Hauer & Feld LLP

New Privacy and Cybersecurity Obligations for Private Fund Sponsors and Managers

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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

Morgan Lewis - ML Benefits

ERISA Cybersecurity Compliance: SEC Proposed Rule May Provide Metrics for Evaluating Certain SEC-Regulated Plan Service Providers

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In 2021, the US Department of Labor (DOL) issued cybersecurity guidance (the DOL Guidance) that sets out the DOL’s views on what processes fiduciaries of benefit plans regulated by the Employee Retirement Income Security Act...more

Lowenstein Sandler LLP

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

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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

WilmerHale

SEC Proposes Changes to Reg S-P to Impose New Cybersecurity-Related Requirements on Covered Institutions

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On March 15, 2023, the Securities and Exchange Commission (SEC) announced proposed changes to Regulation S-P (“Reg S-P”) that would impose new cybersecurity incident response requirements on broker-dealers, investment...more

Goodwin

SEC Proposes Changes to Reg S-P to Enhance Protection of Customer Information

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In this Weekly Roundup Issue. The Securities and Exchange Commission (SEC) proposed changes to Reg S-P to enhance protection of customer information, and reopened the comment period on proposed cybersecurity rules and...more

Holland & Knight LLP

Changing of the Guard? SEC Proposes Significant Amendments to the Safeguards Rule

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The SEC continued its recent onslaught of proposed cybersecurity rules in mid-March with three new proposals covering a litany of entities, including investment advisers, broker-dealers, investment companies, clearing...more

Kramer Levin Naftalis & Frankel LLP

SEC Proposes Data Breach Notification and Incident Response Requirements

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On March 15, 2023, the Securities and Exchange Commission (SEC) proposed three rule changes that demonstrate its continued focus on cybersecurity. One of these proposals, and the only one to be unanimously approved (the...more

Seward & Kissel LLP

SEC Proposes New Cybersecurity Requirements for Certain Market Entities and Reopens Comment Period for Proposed Cybersecurity...

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Quick Take: The SEC proposed new requirements for several different market entities designed to mitigate cybersecurity risk, including requirements relating to written policies and procedures and notifications about...more

Faegre Drinker Biddle & Reath LLP

The SEC’s Most Detailed Cybersecurity Guidance to Date

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The SEC, through its Office of Compliance Inspections and Examinations (“OCIE”), recently issued its most detailed cyber guidance to date. OCIE had previously issued several cybersecurity risk alerts over the past few years....more

Bracewell LLP

SEC Examiners Release Cyber Observations: What You Need To Know

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On January 27, 2020, the SEC’s Office of Compliance Inspections and Examinations (OCIE) announced its most recent Cybersecurity and Resiliency Observations. This report highlights specific practices that have been, and can be...more

Akin Gump Strauss Hauer & Feld LLP

SEC Warns Registered Firms about Client Privacy and Data Security

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• The SEC released a Risk Alert summarizing key areas in which it continues to see compliance deficiencies related to Regulation S-P, the primary SEC rule regarding privacy notices and safeguard policies of investment...more

UB Greensfelder LLP

The SEC Released A Risk Alert On Reg S-P, a/k/a How To Avoid A $1 Million Penalty

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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

Sheppard Mullin Richter & Hampton LLP

SEC To Focus on Cybersecurity in 2019

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For the fourth year running, the Securities and Exchange Commission’s Office continues to list cybersecurity as one of the top enforcement priorities for 2019. As it relates to cybersecurity, the SEC will be focusing on...more

Perkins Coie

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

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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

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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

K&L Gates LLP

OCIE’s 2015 Cybersecurity Examination Initiative

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On September 15, 2015, the Securities and Exchange Commission’s (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”) released a Risk Alert (the “2015 Risk Alert”) that announced its second round of cybersecurity...more

Bracewell LLP

SEC: 2015 Examination Priorities – Cybersecurity Compliance and Controls

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Registered broker-dealers and investment advisers received a stern warning to strengthen their cybersecurity programs or face further regulatory scrutiny. On September 15, 2015, the SEC announced a plan to sharpen its focus...more

Carlton Fields

SEC Continues to Focus on Cybersecurity Risks

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On September 15, the U.S. Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) issued a risk alert regarding the SEC’s ongoing cybersecurity examinations of registered broker-dealers...more

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