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Seward & Kissel LLP

SEC Adopts Data Privacy Rule Amendments to Regulation S-P

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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

Keating Muething & Klekamp PLL

Benefits Monthly Minute - December 2023

Happy Holidays! The December Monthly Minute includes a fiduciary checkup reminder and a look at HHS’ recent settlement stemming from a phishing attack that impacted ePHI of nearly 35,000 individuals....more

Troutman Pepper

SEC Issues Risk Alert on Safeguarding Customer Records and Information at Branch Offices

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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

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

Foley Hoag LLP - White Collar Law &...

White Collar Year in Preview: SEC Enforcement Trends in 2020

Editors’ Note: This is the first in our start-of-year series examining important trends in white collar law and investigations in the coming year. Up next: a look at trends in health care enforcement. Look for additional...more

Akin Gump Strauss Hauer & Feld LLP

CFTC Settlement Asserts Data Breach Disclosure Requirement for Future Commission Merchants

On September 12, 2019, the Commodity Futures Trading Commission (CFTC) announced a settlement with Phillip Capital Inc. (PCI or the “Company”), a registered futures commission merchant (FCM), after hackers successfully...more

Akin Gump Strauss Hauer & Feld LLP

SEC Warns Registered Firms about Client Privacy and Data Security

• 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

Sheppard Mullin Richter & Hampton LLP

SEC To Focus on Cybersecurity in 2019

For the fourth year running, the Securities and Exchange Commission’s Office continues to list cybersecurity as one of the top enforcement priorities for 2019. As it relates to cybersecurity, the SEC will be focusing on...more

Patterson Belknap Webb & Tyler LLP

SEC Cyber Briefing: Enforcement Expectations for 2019

In our second installment of a three-part series, we look at the U.S. Securities and Exchange Commission’s cyber-related enforcement actions in 2018....more

Sheppard Mullin Richter & Hampton LLP

SEC Issues $1 Million Identity Theft Rule Fine

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

Stinson - Corporate & Securities Law Blog

SEC Cybersecurity Disclosure and Controls Checklist

In February 2018 the SEC outlined its views with respect to cybersecurity disclosure requirements under the federal securities laws as they apply to public reporting companies. Set forth below is a checklist of items included...more

Kramer Levin Naftalis & Frankel LLP

SEC Guidance Focuses on Cybersecurity Procedures and Disclosure Issues

On Feb. 21, the Securities and Exchange Commission (SEC) released interpretive guidance on public companies’ disclosure practices regarding cybersecurity breaches and risks to the public....more

Fenwick & West LLP

SEC Releases Updated Cybersecurity Guidance

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The U.S. Securities and Exchange Commission on Feb. 21, 2018, issued interpretive guidance on public company cybersecurity disclosures. The new guidance will affect public companies and companies seeking to go public in...more

Ballard Spahr LLP

SEC Releases Guidance on Cybersecurity Disclosures

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In light of the increasing significance of cybersecurity incidents, and their potential impact on a company's operations, on February 21, the Securities and Exchange Commission (SEC) issued guidance to public reporting...more

Snell & Wilmer

Colorado’s Proposed Cybersecurity Rules for Investment Advisers and Broker-Dealers

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Colorado has new proposed rules that add cybersecurity requirements for certain entities with Colorado securities licenses. The proposed rules are from the regulatory agency the Division of Securities. It licenses securities...more

Manatt, Phelps & Phillips, LLP

Corporate Investigations & White Collar Defense - October 2015

"Wherefore Art Thou Due Process?" Part III - Why it matters: It is time for another installment in our continuing "Wherefore Art Thou Due Process?" coverage into the ongoing constitutional challenges to the SEC's...more

Robinson+Cole Data Privacy + Security Insider

SEC brings first cybersecurity-related enforcement action

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

Perkins Coie

SEC’s Increased Cybersecurity Enforcement and How to Reduce Your Risks

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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

BakerHostetler

The SEC OCIE Announces Increased Scrutiny of Broker-Dealers’ and Investment Advisers’ Cybersecurity Programs

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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

Carlton Fields

Investment Adviser Settles SEC Charges After Data Breach

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Last week, the Securities and Exchange Commission (SEC) settled charges against a registered investment adviser for failing to comply with Rule 30(a) of Regulation S-P (17 C.F.R. § 248.30(a)) (“Safeguards Rule”). The...more

Burr & Forman

SEC Shows It’s Serious About Cyber Security

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A week after OCIE announced it would conduct a second round of cyber-security exams, the Commission emphasized the issue by bringing an enforcement action against a non-custodial investment-adviser over a remediated data...more

Troutman Pepper

SEC Releases First Cybersecurity Enforcement Action for Failure to Protect Client Data

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The SEC’s focus in the action was not on the manner of the firm’s responses to the breach or whether there was any actual harm, but predominantly on the adequacy of the firm’s written policies for safeguarding customer...more

King & Spalding

Unprecedented Hacking and Trading Scheme Highlights Key Cybersecurity Lessons

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On Aug. 11, 2015, federal prosecutors in the District of New Jersey and the Eastern District of New York unsealed indictments against nine individuals in the U.S. and Ukraine who were allegedly involved in a five-year,...more

Alston & Bird

SEC Provides Additional Information On Cybersecurity Examinations

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On September 15, 2015, the Security and Exchange Commission’s Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert to provide additional information on the areas of focus for its second round of...more

Foley Hoag LLP

OCIE’s 2015 Cybersecurity Examination Initiative

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Second Round of Cybersecurity Examinations to Begin - On September 15, 2015, the Office of Compliance Inspections and Examinations (OCIE) of the Securities and Exchange Commission (SEC) issued a Risk Alert announcing a...more

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