Podcast: Private Fund Regulatory Update – Network and Cloud Storage
Compliance into the Weeds-Episode 39, Disclosure of Ransomware Attacks
On April 22, 2025, Laura D’Allaird, Chief of the SEC’s Cyber and Emerging Technologies Unit (CETU), participated in the Incident Response Forum Masterclass 2025 (Incident Response Masterclass). In the session, titled “SEC...more
There has been a lot of conjecture that the SEC may become friendlier to registrants because of the new administration. Given the SEC’s mandate to protect the investing public, however, we do not expect SEC examiners to...more
After its fiscal year-end frenzy in September, the SEC relaxed slightly, with no new rule-making and fewer enforcement actions. So, I took a break last month and combined the October and November Roundups. (You’re welcome.)...more
On May 15, 2024, the SEC announced it would make amendments to Regulation S-P (Reg S-P). This will be the first amendment to the regulation since its adoption 24 years ago in 2000. The regulation focuses on how institutions...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
This RIA Regulatory Review highlights certain key regulatory developments affecting investment advisers....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
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
On August 30, 2021, the Securities and Exchange Commission (SEC) announced that eight broker-dealers and/or investment advisers will pay civil monetary penalties to resolve enforcement actions arising from cybersecurity...more
REGULATORY UPDATES - Investors Continue to Press Regulators for Disclosure of Environmental, Social, and Governance (“ESG”) Risks...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 every investment adviser, broker-dealer, and fund (and their lawyer) knows, noncompliance with Regulation S-P, the SEC’s primary rule on privacy notices and safeguard policies, can land a registrant in hot and expensive...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
In September 2018, the Securities and Exchange Commission (“SEC”) announced that broker-dealer and investment adviser Voya Financial Advisors Inc. (“VFA”) agreed to pay $1,000,000 to settle charges related to alleged failures...more
The Security and Exchange Commission’s (“SEC”) recent $1 million settlement with Morgan Stanley Smith Barney LLC (“MSSB”) marked a turning point in the agency’s focus on cybersecurity issues, an area that the agency has...more
As our last newsletter highlighted, the government is ramping up enforcement investigations against both regulated entities and public companies for perceived cybersecurity failures. Proving the point, on September 22, 2015,...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
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 22, the Securities and Exchange Commission (SEC) announced that it had entered into a settlement order with R.T. Jones Capital Equities Management, Inc. (R.T. Jones), a St. Louis-based SEC registered investment...more
Just one week after the Securities and Exchange Commission (SEC) Office of Compliance Inspections and Examinations issued a new risk alert on cybersecurity, the SEC brought an enforcement action against an investment adviser...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
Cybersecurity has increasingly become a critical issue for all types of businesses, few more so than broker-dealers, investment advisers and others in the financial sector. The cyber threat is much broader than customer data...more
Few topics are as hot as cybersecurity. Recent high-profile data breaches at national retailers have made cybersecurity a frequent topic on Capitol Hill and an issue of growing concern to average Americans. Not surprisingly,...more