News & Analysis as of

Gramm-Leach-Blilely Act Regulation S-P

Dechert LLP

SEC Adopts First Major Amendments to Regulation S-P Since 2000

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Incident Response Plans and Written Information Security Programs Continue to be Essential and Will Need to Be Reviewed. Most sophisticated organizations currently have in place incident response plans. Those organizations...more

Orrick, Herrington & Sutcliffe LLP

SEC Amends Privacy Rule to Establish Data Breach Notification Standard

The Securities and Exchange Commission (SEC) has amended its privacy rule – Regulation S-P – to establish a federal minimum standard for covered institutions to notify affected individuals of a data breach....more

Davis Wright Tremaine LLP

SEC Adopts Amendments to Regulation S-P That Require Reporting Breaches of "Sensitive Customer Information"

On May 15, the Securities and Exchange Commission adopted amendments to Regulation S-P, which covers broker-dealers, registered investment advisors (RIAs), and investment companies (funds). These entities are now required to...more

Vinson & Elkins LLP

Cyber(in)security: New York Levies Fine for Failure to Implement Written Policies

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On November 27, 2023, the New York State Department of Financial Services (“DFS”) and First American Title Insurance Company (“First American”) entered into a consent order1 that resolved litigation over First American’s...more

Dechert LLP

SEC Proposes Robust Amendments to Regulation S-P

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At an open meeting on March 15, 2023, the U.S. Securities and Exchange Commission voted unanimously to propose rule amendments to Regulation S-P (Proposed Rule) and published an accompanying release (Release). The Proposed...more

Davis Wright Tremaine LLP

SEC Proposes Host of New Rules for Data Security, Cybersecurity, and IT Resilience

The Securities and Exchange Commission (SEC or Commission) voted on March 15, 2023, to propose three new sets of rules for data security, cybersecurity, and IT operational resilience. The newly proposed rules would, among...more

Dechert LLP

Dechert Cyber Bits - Issue 22

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SEC Chair Gensler Indicates Commission is Looking to Update SEC’s Regulation S-P - On September 28, 2022, Securities and Exchange Commission (“SEC” or the “Commission”) Chairman Gary Gensler appeared via video at the...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring Articles on FINRA's New Office of Financial Innovation and a Proposal From the...

BROKER-DEALER - OCIE Issues Risk Alert on Investment Adviser and Broker-Dealer Compliance Issues Related to Regulation S-P - On April 16, the Office of Compliance Inspections and Examinations (OCIE) of the Securities...more

Alston & Bird

Cybersecurity Preparedness & Response Alert: Effective Cybersecurity: The Evolving Regulatory Landscape for Investment Advisers,...

Alston & Bird on

Cybersecurity has become a top concern for executives and boards across all sectors of commerce and critical infrastructure that rely on digital technologies—including financial services—and investment advisers, investment...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

Brooks Pierce

What's So Great About an Information Security Policy?

Brooks Pierce on

Lawyers and compliance professionals constantly tout the importance of internal information security policies, particularly in light of data privacy problems that are reported almost daily in the media. Admittedly, drafting...more

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