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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
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
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
On March 15, 2023, the U.S. Securities and Exchange Commission (“SEC”) released its proposal to amend Regulation S-P: Privacy of Consumer Financial Information and Safeguarding Customer Information (the “Proposed...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
SEC Tells Firms to Stop Missing the Basics on Cybersecurity - The SEC’s Office of Compliance Inspections and Examinations (OCIE) reported in a recent Risk Alert that many investment advisers and broker-dealers are failing to...more
On May 29, Nevada passed Senate Bill 220 (SB 220), which amends its existing privacy law and provides consumers with the right to opt-out of the "sale" of their personal information. The law offers a new definition of "sale,"...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
The SEC has again signaled that now is the time for investment advisers and broker-dealers to get serious about compliance with Reg. S-P. For years, the SEC’s examination priorities have included a focus on cybersecurity...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
One of the most common things we discuss with clients is the need to ensure that privacy policies accurately reflect the actual procedures in place for handling confidential information. The SEC reiterated that point last...more
With California enacting a sweeping new data privacy law on June 28, now is the time for companies to review and adjust to how the California Consumer Privacy Act will impact their business. The act, which has broad...more
California has become the first state to introduce privacy protection for individuals’ personal data comparable to that provided under the European Union’s General Data Protection Regulation (GDPR). The California Consumer...more
As most people started to wind down for the July 4th holiday week, California was just ramping up its “as California goes” focus on data privacy. On June 28, 2018, California passed a comprehensive data privacy bill that has...more