On January 28, 2020, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) released a detailed set of observations culled from thousands of examinations of registered investment advisers, broker-dealers,...more
Our Cybersecurity Preparedness & Response Team breaks down the ways in-house counsel can demonstrate compliance with the California Consumer Privacy Act to regulators and business partners....more
As independent auditors to public companies and business development companies begin to make required disclosure of Critical Audit Matters (CAMs) to the audit committee, such reports are beginning to include discussion of...more
The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) has issued a Risk Alert that provides an overview of the most common deficiencies or weaknesses in investment adviser and broker-dealer compliance with the...more
4/19/2019
/ Broker-Dealer ,
Cybersecurity ,
Data Protection ,
Data Security ,
Investment Adviser ,
OCIE ,
Policies and Procedures ,
Popular ,
Regulation S-P ,
Risk Alert ,
Securities and Exchange Commission (SEC)
On February 28 and March 13, 2019, members of the U.S. Senate and U.S. House of Representatives introduced legislation designed to enhance the transparency of cybersecurity risk oversight at certain SEC reporting companies. ...more
The February 15, 2019 NYDFS compliance certification deadline represents the last annual compliance certification subject to the transition period for covered entities to come into compliance with the cybersecurity...more
On December 28, 2018, the Department of Health and Human Services (HHS) issued new voluntary cybersecurity guidance for the health care industry titled, “Health Industry Cybersecurity Practices: Managing Threats and...more
Michigan enacted the Michigan Data Security Act on December 28, 2018, imposing stringent cybersecurity measures on any person (individual or corporate) licensed by the Michigan Department of Insurance and Financial Services. ...more
The Securities and Exchange Commission issued an investigative report last week cautioning public companies to consider cyber incidents and threats when implementing internal accounting controls. ...more
September 4, 2018 marks the end of the transitional period for covered entities to comply with several key provisions of the NYDFS Cybersecurity Requirements that require certain systemic and sustained measures....more
Investment advisers and broker-dealers can expect more scrutiny of their data security from the Securities and Exchange Commission. Our Cybersecurity Preparedness & Response and Investment Management, Trading & Markets teams...more
Our Privacy & Data Security Group reviews the Eleventh Circuit’s decision narrowing the FTC’s authority to impose broad cybersecurity measures on defendants, but cautions it would be a mistake to interpret the ruling as...more