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Cybersecurity › Regulation S-P › Policies and Procedures

Follow this channel for advisories on one of the biggest threats to businesses today. Read a morning brief of fresh guidance and commentary by leading lawyers on security, privacy, risk... more +
Follow this channel for advisories on one of the biggest threats to businesses today. Read a morning brief of fresh guidance and commentary by leading lawyers on security, privacy, risk management, global regulations, data protection, leaks, hacking, cyber insurance, compliance, HIPAA, and every other aspect of cybersecurity of import to corporate readers right now.   less -
Latham & Watkins LLP

SEC Imposes New Cybersecurity Requirements on Broker-Dealers, Investment Companies, Registered Investment Advisers, and Transfer...

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Covered institutions will need to review their cybersecurity and incident response policies and procedures ahead of the applicable compliance deadline. ...more

Jenner & Block

Client Alert: The SEC Expands Its Cybersecurity Oversight by Adopting Regulation S-P Amendments

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Earlier this month, approximately one year after releasing its proposed amendments to Regulation S-P, the SEC announced the adoption of final amendments to Regulation S-P, expanding the information protected, the policies and...more

SEC Compliance Consultants, Inc. (SEC³)

Regulatory Roundup for May 2024

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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

Foley Hoag LLP - Security, Privacy and the...

SEC Revamps and Enhances Data Protections with Amendments to Regulation S-P

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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

Hinckley Allen

Final Amendments to Regulation S-P under Securities Exchange Act of 1934

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On May 15, 2024, the Securities and Exchange Commission (the “SEC”) issued final amendments (the “Amendments”) to Regulation S-P (originally adopted in 2000), which governs the treatment of a customer’s nonpublic personal...more

Akin Gump Strauss Hauer & Feld LLP

New Privacy and Cybersecurity Obligations for Private Fund Sponsors and Managers

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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

Goodwin

SEC to Impose Significant New Privacy and Cybersecurity Rules for BDs, RIAs, TAs, and Mutual Funds

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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

Vinson & Elkins LLP

SEC Proposes New Cybersecurity Rules for Market Entities

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On March 15, 2023, the Securities Exchange Commission (“SEC”) issued three additional proposed rules that would expand the reach of the agency’s current cybersecurity guidance to new entities and augment existing...more

Proskauer - The Capital Commitment

SEC Revisits Regulation S-P After Twenty Years of Innovation to Information Technology

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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

Lowenstein Sandler LLP

Investment Advisers, Broker-Dealers, and Other Financial Industry Participants Take Note: SEC Demonstrates Commitment to...

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On March 15, 2023, the Securities and Exchange Commission (“SEC”) issued three releases proposing (i) amendments to Regulation S-P (“Regulation S-P Proposal”)1, (ii) amendments to Regulation SCI (“Regulation SCI Proposal”)2,...more

Paul Hastings LLP

SEC Proposes New Cybersecurity Rule and Amendments

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On March 15, 2023, the SEC issued proposed amendments and a proposed rule addressing cybersecurity. Specifically, the SEC proposed Rule 10, which addresses cybersecurity risks, and proposed to amend Regulation SCI and...more

Goodwin

SEC Proposes Changes to Reg S-P to Enhance Protection of Customer Information

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In this Weekly Roundup Issue. The Securities and Exchange Commission (SEC) proposed changes to Reg S-P to enhance protection of customer information, and reopened the comment period on proposed cybersecurity rules and...more

Holland & Knight LLP

Changing of the Guard? SEC Proposes Significant Amendments to the Safeguards Rule

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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

Lowenstein Sandler LLP

SEC Proposes Rash of New Rules on Cybersecurity

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In its efforts to address cybersecurity risks, the U.S. Securities and Exchange Commission (“SEC”) continues to propose rules on cybersecurity. Most recently, on March 15, 2023, the SEC announced its proposal of three...more

Seward & Kissel LLP

Wealth Management Firm Charged with Reg S-P Violations for Failing to Properly Dispose of its Hard Drives

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On September 20th, 2022, the Securities and Exchange Commission (“Commission”) entered a settled order (“Order”) against the wealth management arm of a global financial services firm (“Firm”) for its failure to protect...more

Vinson & Elkins LLP

The SEC Wants You to Take Out the Trash – Securely

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In a recent Securities and Exchange Commission (“SEC”) enforcement action, the SEC concluded that a registered broker-dealer and investment adviser (the “Firm”) violated Rule 30 of Regulation S-P by failing to adopt...more

Goodwin

SEC Makes Cybersecurity Top Priority; Sanctions Firms for Cybersecurity Failures

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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

Akin Gump Strauss Hauer & Feld LLP

SEC Cyber Enforcement Actions – Lessons for Private Fund Managers

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On August 30, 2021, the Securities and Exchange Commission announced three enforcement actions against registered investment advisers for alleged cybersecurity failures involving cloud-based email systems. All three actions...more

Proskauer - The Capital Commitment

Privacy in the Time of Pandemic: COVID-19 Provides Opportunity to Revisit Regulation S-P Privacy Policies

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With more people working remotely than ever before in light of COVID-19, firms in the private equity and hedge fund space should review their Regulation S-P privacy and information-safeguarding policies to ensure they are...more

Carlton Fields

On Cybersecurity, Grab the Low-Hanging Fruit

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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

Akin Gump Strauss Hauer & Feld LLP

SEC OCIE Issues Guidance on Advisors’ and Broker-Dealers’ Cloud-Based and Other Network Storage of Customer Data

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• On May 23, 2019, the Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert describing its observations in past examinations of weaknesses and best practices...more

Faegre Drinker Biddle & Reath LLP

U.S. Securities and Exchange Commission Issues Risk Alert Regarding Safeguarding Customer Records and Information Stored on...

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On May 23, 2019, the United States Securities and Exchange Commission (“SEC”)’s Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert entitled “Safeguarding Customer Records and Information in Network...more

Nelson Mullins Riley & Scarborough LLP

OCIE Issues Guidance on Regulation S-P

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The Office of Compliance Inspections and Examinations (the “OCIE”) issued a risk alert that provides guidance to broker-dealers and investment advisors for complying with the requirements of Regulation S-P on April 16, 2019. ...more

Baker Donelson

SEC Issues Risk Alert on Regulation S-P

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It should not be surprising to anyone that cybersecurity and data protection remain top priorities for regulators of the financial services industry. Indeed, cybersecurity has been regularly identified as a key priority by...more

Sands Anderson PC

Helpful Safeguards Information for Investment Advisers and Broker-Dealers – Straight From the Examiners!

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When it comes to information security, the Safeguards Rule of Regulation S-P (Safeguards Rule) requires SEC-registered investment advisers and brokers and dealers (Registrants) to adopt written policies and procedures that...more

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