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Data Security Investment Adviser Risk Alert

Goodwin

SEC EXAMS Division Issues Reg. S-ID Risk Alert

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The SEC Division of Examinations recently published a risk alert summarizing observations from exams of registered investment advisers and broker-dealers related to compliance with Reg. S-ID, which is generally designed to...more

Dechert LLP

OCIE Issues Cybersecurity Risk Alert on the Risk of Credential Stuffing Attacks

Dechert LLP on

The Risk Alert makes clear that OCIE has observed an increase in the frequency of credential stuffing attacks against Registrants, including some successful credential stuffing attacks that resulted in the loss of customer...more

Sheppard Mullin Richter & Hampton LLP

SEC Issues Alert On Outsourcing and Data Security

The SEC recently issued a risk alert warning about using vendors and cloud-based platforms. Many broker dealers and investment advisors are turning to these third parties to store customer data. In its alert, the SEC’s Office...more

Akin Gump Strauss Hauer & Feld LLP

SEC OCIE Issues Guidance on Advisors’ and Broker-Dealers’ Cloud-Based and Other Network Storage of Customer Data

• On May 23, 2019, the Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert describing its observations in past examinations of weaknesses and best practices...more

Faegre Drinker Biddle & Reath LLP

U.S. Securities and Exchange Commission Issues Risk Alert Regarding Safeguarding Customer Records and Information Stored on...

On May 23, 2019, the United States Securities and Exchange Commission (“SEC”)’s Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert entitled “Safeguarding Customer Records and Information in Network...more

Baker Donelson

SEC Issues Risk Alert on Regulation S-P

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It should not be surprising to anyone that cybersecurity and data protection remain top priorities for regulators of the financial services industry. Indeed, cybersecurity has been regularly identified as a key priority by...more

Sheppard Mullin Richter & Hampton LLP

SEC Issues Risk Alert on Customer Privacy Safeguards

Earlier this month, the Securities and Exchange Commission (“SEC”) took a break from its recent focus on digital assets and the Best Interest fiduciary standard to publish a Risk Alert encouraging investment advisers and...more

Akin Gump Strauss Hauer & Feld LLP

SEC Warns Registered Firms about Client Privacy and Data Security

• 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

Patterson Belknap Webb & Tyler LLP

SEC Warns Advisers Over Privacy Compliance Issues

The Securities and Exchange Commission is warning investment firms to step up their game when it comes to following the agency’s privacy rules. In a Risk Alert issued by the Office of Compliance Inspections and Examinations...more

McGuireWoods LLP

SEC OCIE Highlights Potential Deficiencies in Firm Privacy Policies

McGuireWoods LLP on

On April 16, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert highlighting Regulation S-P compliance deficiencies and issues it found in recent examinations of broker-dealers and...more

UB Greensfelder LLP

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

UB Greensfelder LLP on

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

BakerHostetler

SEC Updates Data Privacy and Cybersecurity Guidance for Registered Firms

BakerHostetler on

On April 16, 2019, the Office of Compliance Inspections and Examinations (OCIE) of the Securities and Exchange Commission (SEC) issued a risk alert, “Investment Adviser and Broker-Dealer Compliance Issues Relating to...more

Fox Rothschild LLP

OCIE Issues Risk Alert Regarding Compliance With Regulation S-P’s Notice And Safeguard Policy Requirements

Fox Rothschild LLP on

On April 16, the Securities and Exchange Commission (SEC)’s Office of Compliance Inspections and Examinations (OCIE) released a new Risk Alert that identifies common compliance issues facing investment advisers and...more

Alston & Bird

SEC Issues Risk Alert Noting Common Regulation S-P Compliance Issues

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The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) has issued a Risk Alert that provides an overview of the most common deficiencies or weaknesses in investment adviser and broker-dealer compliance with the...more

Dechert LLP

OCIE Publishes Risk Alert on the Use of Electronic Messaging by Investment Advisers and Employees

Dechert LLP on

The U.S. Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) issued a National Exam Program Risk Alert on December 14, 2018 concerning the use of electronic messaging by registered...more

Skadden, Arps, Slate, Meagher & Flom LLP

OCIE Releases Results of Cybersecurity Examination Initiative

On August 7, 2017, the Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission (SEC) released a summary of its observations (the report) from cybersecurity examinations of 75...more

BakerHostetler

SEC Cybersecurity Risk Alert Emphasizes Proactive Compliance and Ongoing Vigilance

BakerHostetler on

On August 7, 2017, the Securities and Exchange Commission (SEC) released its latest cybersecurity risk alert, detailing findings from the examination of 75 broker-dealers, investment advisers and investment companies carried...more

Patterson Belknap Webb & Tyler LLP

SEC Watch: “Observations” from SEC’s Cybersecurity 2 Initiative

Last week, the U.S. Securities and Exchange Commission’s (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”) released its “Observations from Cybersecurity Examinations” conducted pursuant to OCIE’s...more

Manatt, Phelps & Phillips, LLP

Corporate Investigations & White Collar Defense - October 2015

"Wherefore Art Thou Due Process?" Part III - Why it matters: It is time for another installment in our continuing "Wherefore Art Thou Due Process?" coverage into the ongoing constitutional challenges to the SEC's...more

Robinson+Cole Data Privacy + Security Insider

SEC brings first cybersecurity-related enforcement action

The Securities and Exchange Commission (“SEC”) recently settled its first cybersecurity-related enforcement action against a Missouri based registered investment adviser, R.T. Jones Capital Equities Management, Inc. (the ...more

Perkins Coie

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

Perkins Coie on

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

BakerHostetler on

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

K&L Gates LLP on

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

Alston & Bird

SEC Provides Additional Information On Cybersecurity Examinations

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On September 15, 2015, the Security and Exchange Commission’s Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert to provide additional information on the areas of focus for its second round of...more

Foley Hoag LLP

OCIE’s 2015 Cybersecurity Examination Initiative

Foley Hoag LLP on

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

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