Podcast: Private Fund Regulatory Update – Network and Cloud Storage
Compliance into the Weeds-Episode 39, Disclosure of Ransomware Attacks
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
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
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
On May 15, 2024, the U.S. Securities and Exchange Commission (the “SEC”) adopted amendments to Regulation S-P (the “Data Privacy Amendments”), which were published in the Federal Register on June 3, 2024, starting the clock...more
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
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
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, 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
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
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
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
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
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
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
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
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
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
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
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
• 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
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
The SEC has again signaled that now is the time for investment advisers and broker-dealers to get serious about compliance with Reg. S-P. For years, the SEC’s examination priorities have included a focus on cybersecurity...more
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