Podcast: Private Fund Regulatory Update – Network and Cloud Storage
Compliance into the Weeds-Episode 39, Disclosure of Ransomware Attacks
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
Virtually all organizations have an obligation to safeguard their personal data against unauthorized access or use, and, in some instances, to notify affected individuals in the event such access or use occurs. Those...more
Who may be interested: Investment Companies; Investment Advisers; Broker-Dealers; Transfer Agents - The SEC adopted amendments to Regulation S-P imposing new data privacy and security requirements on broker-dealers,...more
On April 26, the SEC’s Division of Examinations (EXAMS) issued a risk alert on the importance of broker-dealers and investment advisers (collectively, “firms”) establishing and following written policies and procedures aimed...more
The Securities and Exchange Commission (SEC or Commission) voted on March 15, 2023, to propose three new sets of rules for data security, cybersecurity, and IT operational resilience. The newly proposed rules would, among...more
There is little doubt that the U.S. Securities and Exchange Commission is making cybersecurity a top priority. SEC Chair Gary Gensler told a Senate committee on Tuesday, September 14, 2021 that the agency is developing a...more
A cyber breach can have serious legal, financial, and reputational consequences for a fund sponsor, as described in our previous post. As such, cybersecurity threats must be treated as business risks, not just a potential IT...more
Are You Ready for Canada’s New Privacy Breach Rules? Mandatory privacy breach notification, reporting, and record-keeping obligations under Canada’s federal data protection law, the Personal Information Protection and...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 Securities and Exchange Commission recently settled with Voya Financial Advisors, Inc. for alleged violation of Regulation S-ID (otherwise known as the Identity Theft Red Flags Rule) and Regulation S-P (otherwise known as...more
On September 22, the U.S. Securities and Exchange Commission (“SEC”) and R.T. Jones Capital Equities Management, Inc. (“R.T. Jones”), a St. Louis-based investment adviser, settled charges that R.T. Jones failed to adopt...more
The Securities and Exchange Commission (“SEC”) recently settled its first cybersecurity-related enforcement action against a Missouri based registered investment adviser, R.T. Jones Capital Equities Management, Inc. (the ...more
Non-Enforcement Cybersecurity Is At the Top of SEC Examination Concerns In a recent SEC “risk alert” for registered broker-dealers and investment advisers, the SEC’s Office of Compliance Inspections and Examinations (OCIE)...more
The SEC announced last week that an investment adviser had agreed to settle charges that it failed to take required steps to protect against and respond effectively to a cybersecurity breach. The action comes on the heels of...more
On September 15, 2015, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) issued a National Exam Program Risk Alert (2015 Risk Alert) to provide broker-dealers and investment...more
In recent years, the SEC has been focused on cybersecurity. It has issued risk alerts, conducted examinations and provided guidance about what the agency sees as widespread weaknesses in many policies and procedures to...more
A registered investment adviser agreed to settle SEC charges that it failed to adopt adequate cybersecurity policies and procedures reasonably designed to protect customer records and information as required by Rule 30(a) of...more
On September 22, 2015, the Securities and Exchange Commission (SEC) announced the settlement of an enforcement action against a St. Louis-based registered investment adviser (Adviser) brought under Rule 30(a) of Regulation...more
With the recent focus by the SEC and FINRA on cybersecurity for broker-dealers and investment advisers as a backdrop, FINRA recently brought and settled an enforcement action under SEC Regulation S-P against broker-dealer...more