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Investment Management and Private Funds Roundtable: TALF 2020 and PPP Update
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Podcast: Questions & Concerns About Documentation: A Conversation with Colin Adams, M-III Partners
In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important SEC enforcement developments from the past month, with links to primary resources. This...more
What is in store for Privacy and Cybersecurity in 2023 - As the year ends, we offer this special edition with predictions for 2023 from each member of the Cyber Bits Partner Committee. Regardless of what happens in 2023, we...more
SEC Division of Examinations Issues Risk Alert on Regulation S-ID and Identity Theft Prevention Programs - On December 5, 2022, the Securities and Exchange Commission (“SEC”) Division of Examinations (“EXAMS”) issued a...more
On March 9, 2022, the U.S. Securities and Exchange Commission (SEC) proposed new rules that would require current and periodic reporting of material cybersecurity incidents as well as more detailed disclosure of cybersecurity...more
On February 9, 2022, the U.S. Securities and Exchange Commission (“SEC”) proposed a package of new rules and amendments to enhance cybersecurity preparedness and improve cyber resilience of investment advisers and investment...more
In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed changes to private fund regulation; the Office of the Comptroller of the Currency (OCC) succeeded in validating its “valid-when-made” rulemaking; the...more
Background - On August 30, 2021, the Securities and Exchange Commission (SEC) sanctioned eight firms in three actions for cybersecurity failures in their policies and procedures that exposed the personal information of...more
There is little doubt that the U.S. Securities and Exchange Commission is making cybersecurity a top priority. SEC Chair Gary Gensler told a Senate committee on Tuesday, September 14, 2021 that the agency is developing a...more
As publicly reported late last week, the Securities and Exchange Commission’s Division of Enforcement (SEC) sent voluntary requests for information to a range of public companies and investment firms seeking voluntary...more
On September 15, 2020, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) issued a cybersecurity risk alert highlighting the increased use of “credential stuffing” attacks against investment advisers and...more
The Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) has published a risk alert, warning SEC-registered investment advisers, brokers and dealers about the increasing use of...more
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
On September 15, 2020, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert highlighting the recent uptick in “credential stuffing” cyber-attacks against SEC-registered investment advisors...more
The SEC's Office of Compliance and Examinations (OCIE) issued a risk alert on July 10th about its observation of an apparent increase in sophistication of ransomware attacks on SEC registrants, including broker-dealers,...more
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
In our second installment of a three-part series, we look at the U.S. Securities and Exchange Commission’s cyber-related enforcement actions in 2018....more
The U.S. Securities and Exchange Commission (SEC) recently announced a consent order settling an enforcement action brought by the SEC against Voya Financial Advisors Inc. (VFA) in connection with a data security incident...more
In February 2018 the SEC outlined its views with respect to cybersecurity disclosure requirements under the federal securities laws as they apply to public reporting companies. Set forth below is a checklist of items included...more
On Feb. 21, the Securities and Exchange Commission (SEC) released interpretive guidance on public companies’ disclosure practices regarding cybersecurity breaches and risks to the public....more
The U.S. Securities and Exchange Commission on Feb. 21, 2018, issued interpretive guidance on public company cybersecurity disclosures. The new guidance will affect public companies and companies seeking to go public in...more
In light of the increasing significance of cybersecurity incidents, and their potential impact on a company's operations, on February 21, the Securities and Exchange Commission (SEC) issued guidance to public reporting...more
Here’s the inside scoop on “Sheltered Harbor,” a “doomsday project” from US banks that they hope will “prevent a run on the financial system should one of them suffer a debilitating cyberattack.” The gargantuan voluntary...more
The Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission (SEC) issued a National Exam Program Risk Alert (Risk Alert) on May 17, 2017 in response to “WannaCry,” the ongoing...more
OCIE Highlights Frequent Topics for Compliance Deficiencies for Investment Advisers - On Feb. 7, 2017, the Securities and Exchange Commission’s (SEC’s) Office of Compliance Inspections and Examinations (“OCIE”) published...more
On June 28, 2016, the Securities and Exchange Commission (the “SEC”) released a proposed rule (the “Proposed Rule”) that would require registered investment advisers (“RIAs”) to adopt written business continuity and...more