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The SEC’s amended Regulation S-P, adopted last year, will soon enhance data privacy protections for broker-dealers, investment companies, registered investment advisors, and transfer agents. The updated rule requires these...more
On May 16, the Securities and Exchange Commission (“SEC”) announced the adoption of amendments to Regulation S-P, aimed at modernizing and enhancing the rules governing the treatment of consumers’ nonpublic personal...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
On May 16, 2024, the U.S. Securities and Exchange Commission (“SEC”) adopted amendments to Regulation S-P (“Reg S-P”) that are intended to help protect investors’ privacy from the “expanded use of technology and corresponding...more
On May 16, 2024, the SEC amended Regulation S-P to impose new data privacy and security requirements on broker-dealers, registered investment advisers, investment companies (whether or not they are registered with the SEC),...more
Last week, the Securities and Exchange Commission imposed expanded privacy and cybersecurity obligations on fund managers and sponsors registered with the SEC as investment advisers. While many registered investment advisers...more
Does anyone else feel like Bill Murray in Groundhog Day, where his character keeps experiencing the same day over and over and over again? It seems like the Federal Trade Commission just amended the Safeguards Rule yesterday,...more
Back in 2021, the FTC announced substantial changes to the Rule that imposed more detailed and rigorous security requirements for covered financial institutions and was largely based on the New York State Department of...more
There are so many factors that go into breach response. Determining the size of the breach, time limitations, legal requirements, notification needs, urgency for containment, and interrupted business operations are just a...more
On July 29, 2022, the New York Department of Financial Services (NYDFS) published the pre-proposed second amendment to its Cybersecurity Regulations, 23 NYCRR 500 (Part 500), that if adopted, would likely require numerous...more
On July 29, the New York Department of Financial Services (NYDFS) released Draft Amendments to its Part 500 Cybersecurity Rules that include a number of significant amendments to the rules, including notification...more
China recently enacted its Personal Information Privacy Law (PIPL), which came into effect November 1, 2021. PIPL has global reach and broadly regulates entities of all industries that process the personal data of Chinese...more
As of January 1, 2020, California became the first state to permit residents whose personal information is exposed in a data breach to seek statutory damages between $100-$750 per incident, even in the absence of any actual...more
Ready for the Inevitable? Barely a day goes by without a data breach hitting the headlines. It is becoming a fact of life for any firm holding data that, from time to time, some of that data might be lost, stolen,...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
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
As attorneys, our livelihood is often heavily dependent upon the keeping of secrets. But in this complex electronic-data driven environment we work in, where physical security via locked doors and piercing alarms may no...more
A corporate crisis is an event that has the potential to cause material harm to a company’s reputation or bottom line. Typically, these crises have a potential liability element, whether because of negligence, oversight,...more
The best way to handle any emergency is to be prepared. When it comes to data breaches incident response plans are the first step organizations take to prepare. Furthermore, many organizations are required to maintain one. ...more
The European Union's General Data Protection Regulation ("GDPR") is arguably the most comprehensive - and complex - data privacy regulation in the world. Although the GDPR went into force on May 25, 2018, there continues to...more
The security breach announced by Equifax Inc. on September 7, 2017, grabbed headlines around the world as Equifax revealed that personal data of roughly 143 million consumers in the United States and certain UK and Canadian...more
From the financial sector to the healthcare industry, and even the security business itself, hackers are creeping their way into business data systems and pilfering personal information. For financial institutions, security...more