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Securities and Exchange Commission (SEC) Data Protection Investment Adviser

Foley Hoag LLP

Important Dates and Reminders for Investment Advisers, Exempt Reporting Advisers, Commodity Trading Advisors and Commodity Pool...

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INVESTMENT ADVISERS - Annual Compliance Reviews - All investment advisers registered with the Securities and Exchange Commission (“SEC”) or at the state level are required to review their compliance policies and...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

Stark & Stark

Understanding the Enhanced Regulation S-P Requirements

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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

Davis Wright Tremaine LLP

Broker Dealer Regulatory Digest - May 2024 - 2

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

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

Mayer Brown

SEC Adopts Amendments to Regulation S-P

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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

Carlton Fields

Preparing for 2024: Encore to 2023’s Cyber and Privacy Extravaganza

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Step right up as we discuss some of 2023’s most notable cybersecurity and privacy regulatory and litigation developments and tips for keeping your program flying high. Regulatory Activity New regulatory requirements now in...more

White & Case LLP

AI Legal News Summer Roundup: Edition 3

White & Case LLP on

Welcome to the third edition of our AI Legal News Summer Roundup! After five class actions were filed between June 28 and July 11 (as reported on in our first edition of this series), on July 21, another class action lawsuit...more

WilmerHale

SEC Proposes Changes to Reg S-P to Impose New Cybersecurity-Related Requirements on Covered Institutions

WilmerHale on

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

Kramer Levin Naftalis & Frankel LLP

SEC Proposes Data Breach Notification and Incident Response Requirements

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

J.S. Held

Off-Channel Communications: How Financial Services Organizations Can Address Regulators’ Latest Target

J.S. Held on

As a number of recent headlines demonstrate, the U.S. Securities and Exchange Commission (SEC) and other regulators have fined and penalized employers and employees in the financial services industry for non-compliance with...more

Goodwin

SEC EXAMS Division Issues Reg. S-ID Risk Alert

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The SEC Division of Examinations recently published a risk alert summarizing observations from exams of registered investment advisers and broker-dealers related to compliance with Reg. S-ID, which is generally designed to...more

Katten Muchin Rosenman LLP

Financial Markets and Funds Quick Take | Issue 9

New DOL Rule Enables Consideration of ESG Factors in Investing, Plus the SEC Continues its ESG Enforcement Push in the Absence of Final SEC Rules - On November 22, the US Department of Labor (DOL) announced a final rule...more

Alston & Bird

SEC Sends a Message to Investment Advisers: Take Secure Data Disposal Seriously

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On September 20, 2022, the Securities and Exchange Commission (SEC) settled an enforcement action with a large, registered investment adviser (the Firm) for alleged violations of the Safeguards Rule and the Disposal Rule of...more

Goodwin

CFPB Publishes Circular Confirming Failure to Safeguard Consumer Data Could Be Unfair in Violation of CFPA

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In This Issue: ..The Consumer Financial Protection Bureau (CFPB) published a Consumer Financial Protection Circular 2022-04 (Circular) in relation to safeguarding consumer data under the Consumer Financial Protection Act...more

Moore & Van Allen PLLC

The Devil Really is in the Details: The SEC Proposed Rule on Cybersecurity Risk Management for Investment Advisors, Registered...

Late last month the Securities and Exchange Commission (“SEC”) charged JP Morgan, UBS and Trade Station with violations of Regulation S-ID based on a range of  inadequacies in their identity theft red flag policies and...more

Alston & Bird

SEC Settles Enforcement Actions with Broker-Dealers and Investment Advisors for Identity Protection Deficiencies

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On July 27, 2022, the Securities and Exchange Commission (SEC) separately settled three enforcement actions with broker-dealers and investment advisers for alleged deficiencies relating to the prevention of customer identity...more

Pillsbury Winthrop Shaw Pittman LLP

Twelve Hours to Get It Right: The SEC Intensifies Its Focus on Cybersecurity

The SEC’s recent enforcement actions, public statements and proposed rulemaking indicate that cybersecurity will be an area of heightened focus for the Gensler Commission. New proposed rules would require public companies...more

Blank Rome LLP

The BR Privacy & Security Download: March 2022

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Welcome to this month's issue of The BR Privacy & Security Download, the digital newsletter of Blank Rome’s Privacy, Security & Data Protection practice. ...more

Holland & Knight LLP

SEC Proposes Substantial New Cybersecurity Requirements for Investment Advisers and Companies

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Following U.S. Securities and Exchange Commission (SEC) Chairman Gary Gensler's recent speech directing the agency to expand cybersecurity requirements on regulated entities, the SEC on Feb. 9, 2022, voted to propose new...more

Morgan Lewis

SEC Proposes Cybersecurity Risk Management Rules for Advisers and Funds

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The US Securities and Exchange Commission (SEC) recently proposed a comprehensive framework of cybersecurity-related rules and amendments for investment advisers and investment companies. Although advisers and funds may have...more

Burr & Forman

SEC Proposes Cybersecurity Rule for Advisers, Investment Companies

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On February 9, the SEC proposed new cybersecurity risk management regulations for investment advisers, registered investment companies (funds), and business development companies....more

Goodwin

SEC Makes Cybersecurity Top Priority; Sanctions Firms for Cybersecurity Failures

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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

BakerHostetler

SEC Cybersecurity Actions Against Registered Firms for Business Email Compromises Emphasize Importance of MFA

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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

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

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