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Expect Focus - Volume II, May 2025

Builder of Investment Models Deviates From Blueprints Employee’s Rogue Remodeling Costs Builder Plenty - The SEC’s recent order instituting administrative and cease-and-desist proceedings (OIP) against registered...more

Expect Focus - Volume I, January 2025

The Mysterious Boundary Beyond Which “Personal” Relationships Jeopardize a Director’s Independence - In a recent enforcement action, the SEC concluded that the relationship between James Craigie and an officer of Church &...more

Expect Focus - Volume IlI, September 2024

Gone With the Wind? Closed-End Funds Risk Extinction - Shares of SEC-registered closed-end funds (CEFs) have long held significant potential advantages for some investors. For example, unlike shares of mutual funds...more

Going Up: SEC Cyber Incident Reporting - Regulation S-P Amendments Take It to Next Level

On May 16, 2024, the SEC breathed new life into its decades-old Regulation S-P, which requires firms to adopt policies and procedures for the protection of customer information and records. The amended rule balloons the...more

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

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

Expect Focus - Volume I, January 2024

Funds Not Caged by SEC Names Rule Amendments: Roaming Room Remains - The SEC recently adopted amendments to its investment company “names” rule that apply to most SEC-registered funds, including underlying funds in which...more

Expect Focus - Volume II, May 2023

For broker-dealers distributing and selling variable annuities, examinations will test for compliance with Reg BI and FINRA Rule 2330 because both standards apply to variable annuity sales. Firms distributing and selling...more

SEC Showers Down Proposed Cybersecurity Rules: 5 Steps for Staying Dry

It’s rainy season for proposed SEC cybersecurity rules. The first watershed was proposed regulations targeting investment companies’ and advisers’ cybersecurity preparedness. See “SEC Plants New Cybersecurity Regulations;...more

Four Takeaways From the SEC's Proposed Cyber Rule for Public Companies

On March 9, the Securities and Exchange Commission (SEC) published a proposed rule, File No. S7-09-22, that would significantly impact public companies' cybersecurity reporting obligations. Among other things, the rule would...more

SEC Plants New Cybersecurity Regulations; Time Will Tell What Will Bloom

It’s planting season for the SEC, and among the seedlings is File Number S7-04-22, a proposed cybersecurity rule intended to increase regulation of advisers’ and investment companies’ cybersecurity preparedness. As currently...more

Regulators Forecast Storm of Cybersecurity Activity

In September and October 2021 alone, the Federal Trade Commission, the New York State Department of Financial Services, and the Securities and Exchange Commission all signaled their plans for a cybersecurity squall....more

OCIE Continues Relentless Cybersecurity Focus

The level of attention that the SEC’s Office of Compliance Inspections and Examinations has been giving to cybersecurity issues can hardly be overstated. ...more

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