Podcast: Private Fund Regulatory Update – Network and Cloud Storage
Compliance into the Weeds-Episode 39, Disclosure of Ransomware Attacks
On May 16, 2024, the Securities and Exchange Commission adopted amendments to Regulation S-P, the regulation that governs the treatment of nonpublic personal information about consumers by certain financial institutions....more
Last month, the Securities and Exchange Commission (the SEC or the Commission) unanimously voted to adopt amendments to Regulation S-P (Reg S-P), which is the SEC’s regulation governing the treatment and safeguarding of...more
Securities and Exchange Commission. Customer ID requirements. On May 13, 2024, SEC and FinCEN proposed a rule designed to make it more difficult for criminal actors to establish customer relationships with investment...more
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
On May 16, 2024, the Securities and Exchange Commission (“SEC”) announced the adoption of amendments to Regulation S-P (“Reg S-P”) that are designed to modernize and enhance the rules governing the treatment and protection of...more
On May 15, 2024, the U.S. Securities and Exchange Commission (“SEC”) adopted amendments (the “Amendments”) to Regulation S-P under the Securities Exchange Act of 1934 (the “Exchange Act”), which governs the treatment of...more
The SEC remains laser-focused on cybersecurity, with the agency recently reopening the comment period on a sweeping rule for investment advisers and investment companies. In addition, the SEC issued proposed enhancements to...more
The US Securities and Exchange Commission (SEC) issued a notice of proposed rulemaking (the Proposal) on March 15 that would require SEC-regulated investment advisers, investment companies, and broker dealers to provide...more
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
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
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
On August 30, 2021, the Securities and Exchange Commission (“SEC”) announced three settled orders against several investment advisers, broker-dealers, and dual registrants for violations of Regulation S-P allegedly resulting...more
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
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
A cyber breach can have serious legal, financial, and reputational consequences for a fund sponsor, as described in our previous post. As such, cybersecurity threats must be treated as business risks, not just a potential IT...more
With more people working remotely than ever before in light of COVID-19, firms in the private equity and hedge fund space should review their Regulation S-P privacy and information-safeguarding policies to ensure they are...more
On January 27, 2020, OCIE issued a report detailing cybersecurity and resiliency observations the staff made after "thousands of examinations of broker-dealers, investment advisers, clearing agencies, national securities...more
SEC Tells Firms to Stop Missing the Basics on Cybersecurity - The SEC’s Office of Compliance Inspections and Examinations (OCIE) reported in a recent Risk Alert that many investment advisers and broker-dealers are failing to...more
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
• 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
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
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
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
On April 16, 2019, the Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert summarizing numerous issues it found in its recent examinations of SEC-registered...more
In this month's Privacy & Cybersecurity Update, we examine several recent U.K.-related cybersecurity developments and the SEC's risk alert reminding investment advisers and broker-dealers to follow through on implementing...more