News & Analysis as of

Regulation S-P Data Privacy

Eversheds Sutherland (US) LLP

Preparing for Regulation S-P and takeaways from the SEC’s session at the Incident Response Forum Masterclass 2025

On April 22, 2025, Laura D’Allaird, Chief of the SEC’s Cyber and Emerging Technologies Unit (CETU), participated in the Incident Response Forum Masterclass 2025 (Incident Response Masterclass). In the session, titled “SEC...more

Tonkon Torp LLP

What the SEC Amendments to Regulation S-P Mean for Your Business

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On May 16, 2024, the SEC adopted amendments to Regulation S-P requiring broker-dealers, registered investment companies, registered investment advisers, funding portals, and transfer agents (collectively, “covered...more

Dinsmore & Shohl LLP

Summary of Regulation S-P Revisions Applicable to Investment Advisers

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On May 15, 2024 the SEC issued Release Nos. 34-100155; IA-6604 (the “Adopting Release”) providing for amendments to the safeguards and disposal rules of Regulation S-P (the “Amendments”). The compliance dates for the...more

Vedder Price

SEC Adopts Regulation S-P Amendments to Enhance Protection of Customer Information

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On May 16, 2024, the SEC adopted amendments to Regulation S-P to enhance and modernize consumer privacy protections in light of technological developments in how individuals’ personal information is collected, shared and...more

WilmerHale

SEC Modernizes Data Protection Rules for Safeguarding Customer Information

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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

Seward & Kissel LLP

SEC Adopts Data Privacy Rule Amendments to Regulation S-P

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Who may be interested: Investment Companies; Investment Advisers; Broker-Dealers; Transfer Agents - The SEC adopted amendments to Regulation S-P imposing new data privacy and security requirements on broker-dealers,...more

Baker Donelson

[Webinar] New Privacy and Cybersecurity Regulations: What Financial Institutions Need to Know to Stay Compliant - June 13th, 10:00...

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The financial services industry has seen a litany of new data privacy and cybersecurity challenges through the first half of 2024. Financial institutions are facing unprecedented compliance hurdles resulting from the...more

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

Carlton Fields

SEC Stirs Its Pot of Cybersecurity Preparedness and Response Proposals

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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

Morgan Lewis

SEC Proposes Cybersecurity Incident Reporting and Broker-Dealer Cyber Risk Management Requirements

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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

Orrick, Herrington & Sutcliffe LLP

SEC proposes new cybersecurity requirements

On March 15, a divided SEC issued several proposed amendments to the agency’s cybersecurity-related rules. The first is a proposed rule that would implement cybersecurity requirements for participants in the securities...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

Fenwick & West LLP

Say What You Do…Do What You Say…Only See What…

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Case Overview - This week’s U.S. Securities and Exchange Commission enforcement cease-and-desist order (Order) In re App Annie Inc., out of the SEC’s San Francisco Regional Office, underscores the importance of taking...more

Akin Gump Strauss Hauer & Feld LLP

SEC Cyber Enforcement Actions – Lessons for Private Fund Managers

On August 30, 2021, the Securities and Exchange Commission announced three enforcement actions against registered investment advisers for alleged cybersecurity failures involving cloud-based email systems. All three actions...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

Proskauer - The Capital Commitment

Privacy in the Time of Pandemic: COVID-19 Provides Opportunity to Revisit Regulation S-P Privacy Policies

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

Mintz - Employment Viewpoints

FINRA Fines Broker-Dealer for Sharing Customer Data with Third-Party Vendor

Kestra Investment Services LLC (“Kestra”) was fined $125,000 by FINRA for sharing personal customer data with a third-party vendor. Kestra had engaged the vendor to assist newly hired brokers with the transfer of customer...more

Latham & Watkins LLP

Alternative Data: Regulatory and Ethical Issues for Financial Services Firms to Consider - March 2020

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Not too long ago, an investment manager looking to invest in a company might conduct due diligence, attend investor relation calls, peruse quarterly or annual filings, and consider standard ratios such as price to earnings...more

BCLP

Digital Asset Exchange Data Exposure Invites Consideration

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On November 1, 2019, Digital Asset Exchange BitMEX announced that a substantial volume of its customers’ email addresses had been inadvertently leaked in email communications. While the precise nationalities and identities of...more

Alston & Bird

The Digital Download – Alston & Bird’s Privacy & Data Security Newsletter – June 2019

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Are You Ready for Canada’s New Privacy Breach Rules? Mandatory privacy breach notification, reporting, and record-keeping obligations under Canada’s federal data protection law, the Personal Information Protection and...more

Baker Donelson

SEC Issues Risk Alert on Regulation S-P

Baker Donelson on

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

Neal, Gerber & Eisenberg LLP

Client Alert: SEC Issues Risk Alert Warning of Privacy Issues Identified in Recent Examinations of Registered Investment Advisers...

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

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

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