Podcast: Private Fund Regulatory Update – Network and Cloud Storage
Compliance into the Weeds-Episode 39, Disclosure of Ransomware Attacks
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
On May 16, 2024, the SEC adopted amendments to Regulation S-P requiring broker-dealers, registered investment companies, registered investment advisers, funding portals, and transfer agents (collectively, “covered...more
In addition to basic blocking and tackling, compliance officers often have the thankless job of performing the annual review of their compliance program required by Advisers Act Rule 206(4)-7....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
In the second part of this legal update series, we summarize the key takeaways from the Division of Examinations’ (Division) 2025 priorities report released on October 21, 2024. The Division remains focused on mainstays like...more
On October 21, 2024, the U.S. Securities and Exchange Commission’s (“SEC”) Division of Examinations (“EXAMS”) announced its 2025 Examination Priorities (the “2025 Priorities”), highlighting areas that it expects to target...more
On October 21, 2024, the Securities and Exchange Commission Division of Examinations published its examination priorities for fiscal year 2025.1 In this alert, we offer ten observations for broker-dealers. Our observations...more
On October 21, 2024, the Division of Examinations (the “Division”) of the U.S. Securities and Exchange Commission (the “SEC”) issued its annual examination priorities for fiscal year 2025. As with its 2024 examination...more
The Securities and Exchange Commission recently announced that it will host a compliance outreach program on November 7, 2024 (see the program’s agenda) on Advisers Act and Investment Company Act related topics. The agenda...more
Covered institutions will need to review their cybersecurity and incident response policies and procedures ahead of the applicable compliance deadline. ...more
On May 16, 2024, the Securities and Exchange Commission adopted amendments to Regulation S-P, the regulation that governs the treatment of nonpublic personal information about consumers by certain financial institutions....more
As addressing cybersecurity issues continues to become a top priority throughout the financial industry, the U.S. Securities and Exchange Commission (SEC) is following suit. The SEC unanimously voted to approve a new set of...more
Last month, the Securities and Exchange Commission (the SEC or the Commission) unanimously voted to adopt amendments to Regulation S-P (Reg S-P), which is the SEC’s regulation governing the treatment and safeguarding of...more
On May 16, 2024, the SEC adopted amendments (the “Amendments”) to Regulation S-P to require SEC-registered investment advisers and broker-dealers (collectively, “Covered Institutions”) to develop, implement, and maintain...more
This RIA Regulatory Review highlights certain key regulatory developments affecting investment advisers....more
SEC DROPS NEW REQUIREMENT FOR INCIDENT RESPONSE PROGRAMS, PROPOSAL FOR RIAS TO ADOPT CIP, SEC EXAMS SHARES MARKETING RULE FAILURES, RIA SLAMMED FOR FAILING TO RETAIN TEXTS, AND SEC WINS ON SHADOW TRADING THEORY - Welcome to...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
Who may be interested: Registered Investment Advisers, Broker-Dealers. Quick Take: The SEC’s Division of Examinations staff (Staff) recently issued a risk alert (Alert) highlighting deficiencies and trends that the Staff...more
The SEC continues its overhaul of cybersecurity, cyber incident reporting, and privacy controls and requirements for industry registrants, their services providers, and corporate America generally. On March 15, 2023, the SEC...more
The SEC continued its recent onslaught of proposed cybersecurity rules in mid-March with three new proposals covering a litany of entities, including investment advisers, broker-dealers, investment companies, clearing...more
On November 19, 2020, the SEC published a risk alert providing an overview of notable compliance issues identified by the agency’s Office of Compliance Inspections and Examinations (“OCIE”) under Rule 206(4)-7 (the...more
On November 1, 2019, Digital Asset Exchange BitMEX announced that a substantial volume of its customers’ email addresses had been inadvertently leaked in email communications. While the precise nationalities and identities of...more
In the inaugural issue of Investment Management Update, we summarize regulatory, litigation and industry developments from February 2019 to May 2019 impacting the investment management sector....more
As cyber security issues continue to escalate and evolve, compliance officers have more opportunities to better protect and defend their organizations from cyber risk. One of compliance officers’ responsibilities is to stay...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