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Investment Adviser Personally Identifiable Information

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

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

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

Kilpatrick

Pushing Reg S-P: SEC Adopts Amendments to Modernize and Enhance Regulation S-P

Kilpatrick on

On May 16, 2024, the Securities and Exchange Commission (“SEC”) approved amendments to Regulation S-P to address unauthorized access to or use of “customer information” (a new defined term). Regulation S-P governs how...more

Katten Muchin Rosenman LLP

December 9 Looms as Compliance Date for Private Investment Funds and Certain Investment Advisers to Comply With New Cybersecurity...

Additional Requirements to Go Into Effect June 9, 2023 - As we discussed in our March 3 Advisory, on October 27, 2021, the Federal Trade Commission (FTC) announced revisions (the 2021 Revisions) to its information...more

Morrison & Foerster LLP

Top 5 SEC Enforcement Developments for September 2022

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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, which was an active one as the SEC...more

Goodwin

SEC Makes Cybersecurity Top Priority; Sanctions Firms for Cybersecurity Failures

Goodwin on

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

Kramer Levin Naftalis & Frankel LLP

SEC Continues Focus on Cybersecurity in Three New Actions Targeting Investment Advisers and Broker Dealers

Demonstrating its continued focus on cybersecurity enforcement, the Securities and Exchange Commission (SEC) announced three new actions on Aug. 30 charging eight firms with maintaining deficient cybersecurity policies and...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Heightens Focus on Cybersecurity

On August 30, 2021, the Securities and Exchange Commission (SEC) announced that eight broker-dealers and/or investment advisers will pay civil monetary penalties to resolve enforcement actions arising from cybersecurity...more

Stinson - Benefits Notes Blog

DOL Issues First Ever Cybersecurity Guidance

On April 14, 2021, the Department of Labor’s (DOL) Employee Benefits Security Administration issued guidance on cybersecurity for the first time to help plan sponsors, fiduciaries, service providers, and participants protect...more

Foley Hoag LLP

SEC Office of Compliance Inspections and Examinations Issues COVID-19 Risk Alert to Broker-Dealers and Investment Advisers

Foley Hoag LLP on

On August 12, 2020, the SEC Office of Compliance Inspections and Examinations (OCIE) published a Risk Alert that identifies potential issues related to the COVID-19 pandemic for SEC-registered investment advisers and...more

Akin Gump Strauss Hauer & Feld LLP

SEC Risk Alert Highlights on COVID-19-Related Compliance Risks and Considerations for Investment Advisers and Broker-Dealers

- The OCIE of the SEC highlights that responses to COVID-19 present important regulatory and compliance issues for SEC registrants, including “heightened risks of misconduct” tied to recent market volatility. - The Risk...more

Troutman Pepper

SEC’s Office of Compliance Inspections and Examinations Issues COVID-19 Risk Alert

Troutman Pepper on

Why It Matters - Broker-dealers and investment advisers should take heed of OCIE’s guidance and assess their compliance policies and procedures accordingly. Compliance should consider, in consultation with their counsel,...more

Proskauer Rose LLP

OCIE's 2020 Exam Priorities — Key Takeaways for Private Fund Managers

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Last week, the SEC's Office of Compliance Inspections and Examinations released its 2020 Exam Priorities with a number of areas of interest to private fund managers. OCIE reported that it examined 15% of registered investment...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - June 2019

In the inaugural issue of Investment Management Update, we summarize regulatory, litigation and industry developments from February 2019 to May 2019 impacting the investment management sector....more

WilmerHale

OCIE Issues Risk Alert Regarding Advisers and Broker Dealers Failing to Comply with Regulation S P

WilmerHale on

On April 16, 2019, the Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) released a new Risk Alert regarding Regulation S-P deficiencies found in recent examinations of...more

Nelson Mullins Riley & Scarborough LLP

OCIE Issues Guidance on Regulation S-P

The Office of Compliance Inspections and Examinations (the “OCIE”) issued a risk alert that provides guidance to broker-dealers and investment advisors for complying with the requirements of Regulation S-P on April 16, 2019. ...more

Sands Anderson PC

Helpful Safeguards Information for Investment Advisers and Broker-Dealers – Straight From the Examiners!

Sands Anderson PC on

When it comes to information security, the Safeguards Rule of Regulation S-P (Safeguards Rule) requires SEC-registered investment advisers and brokers and dealers (Registrants) to adopt written policies and procedures that...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

Katten Muchin Rosenman LLP

Not So Secure: OCIE Identifies Regulation S-P Compliance Issues

On April 16, the SEC's Office of Compliance Inspections and Examinations (OCIE) published a Risk Alert outlining issues related to compliance with Regulation S-P that it identified in its inspections of SEC-registered...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

Katten Muchin Rosenman LLP

Bridging the Week - April 2019 #3

The watchdog arm of the Securities and Exchange Commission – the Office of Compliance Inspections and Examinations – issued a Risk Alert summarizing breakdowns in compliance by broker-dealers and investment advisers of their...more

Eversheds Sutherland (US) LLP

Decoding Regulation S-P – What noncompliance looks like and what it will cost you

As every investment adviser, broker-dealer, and fund (and their lawyer) knows, noncompliance with Regulation S-P, the SEC’s primary rule on privacy notices and safeguard policies, can land a registrant in hot and expensive...more

Jones Day

SEC Adopts FAST Act Amendments to Modernize and Simplify Disclosure Requirements

Jones Day on

The Situation: The U.S. Securities and Exchange Commission ("SEC") adopted amendments to modernize and simplify disclosure requirements in Regulation S-K and certain related rules and forms. The Result: The amendments seek...more

Sheppard Mullin Richter & Hampton LLP

SEC Issues $1 Million Identity Theft Rule Fine

The Securities and Exchange Commission recently settled with Voya Financial Advisors, Inc. for alleged violation of Regulation S-ID (otherwise known as the Identity Theft Red Flags Rule) and Regulation S-P (otherwise known as...more

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