News & Analysis as of

Broker-Dealer Policies and Procedures Information Governance

Eversheds Sutherland (US) LLP

No good deed goes unpunished: FINRA punishes firm for failing to supervise use of approved off-channel communications

FINRA recently sanctioned, through a Letter of Acceptance, Waiver and Consent (AWC), a broker-dealer for off-channel communications—not because financial professionals texted or used instant messaging when they weren’t...more

Troutman Pepper Locke

SEC’s Office of Compliance Inspections and Examinations Issues COVID-19 Risk Alert

Troutman Pepper Locke on

Why It Matters - Broker-dealers and investment advisers should take heed of OCIE’s guidance and assess their compliance policies and procedures accordingly. Compliance should consider, in consultation with their counsel,...more

Bracewell LLP

SEC Examiners Release Cyber Observations: What You Need To Know

Bracewell LLP on

On January 27, 2020, the SEC’s Office of Compliance Inspections and Examinations (OCIE) announced its most recent Cybersecurity and Resiliency Observations. This report highlights specific practices that have been, and can be...more

Herbert Smith Freehills Kramer

OCIE Warns That Investment Advisers and Broker-Dealers Are Putting Investor Information at Risk

The SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a risk alert warning that investment advisers and broker-dealers “[do] not always use the available security features” on various network storage...more

Proskauer on Privacy

SEC Cybersecurity Update

Proskauer on Privacy on

Results from the SEC’s First Round of Cybersecurity Examinations - On February 3, 2015, the OCIE published a risk alert summarizing its findings from its examinations of over 100 registered investment advisers and...more

Snell & Wilmer

SEC Announces Second Wave of Cyber Exams of Broker Dealers and Advisors – Is Your Firm Ready?

Snell & Wilmer on

In April 2014, the Securities and Exchange Commission’s (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert announcing its first cybersecurity sweep initiative. Pursuant to that initiative,...more

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