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Disclosure Requirements Investment Adviser Cybersecurity

Carlton Fields

Going Up: SEC Cyber Incident Reporting - Regulation S-P Amendments Take It to Next Level

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On May 16, 2024, the SEC breathed new life into its decades-old Regulation S-P, which requires firms to adopt policies and procedures for the protection of customer information and records. The amended rule balloons the...more

Paul Hastings LLP

Public Company Watch: July 2024

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In the July edition of our Public Company Watch, we cover key issues impacting public companies, including the new Compliance and Disclosure Interpretations related to the cybersecurity disclosure rules and the recent SEC...more

Katten Muchin Rosenman LLP

New Rules for Investment Advisers and Brokers Relating to Cybersecurity Breaches

On May 16, the Securities and Exchange Commission (SEC) unanimously approved amendments to Regulation S-P, which imposes new rules relating to cybersecurity breaches involving investment advisers and brokers. Larger entities...more

Eversheds Sutherland (US) LLP

FinCEN and SEC propose Customer Identification Program requirements for investment advisers

Earlier this month, the Financial Crimes Enforcement Network (FinCEN) continued its efforts to require registered investment advisers (RIAs) and exempt reporting advisers (ERAs) to take steps to prevent the laundering of...more

Carlton Fields

Expect Focus - Volume II, May 2024

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Last Lap in SEC RILA Rulemaking Critical Unresolved Issues - Congress directed the SEC to adopt a new registration statement for registered indexed annuities (RILAs) by the end of June. Several months ago, the SEC...more

Davis Wright Tremaine LLP

Investment Adviser Expectations in 2024

Like many other industries, Registered Investment Advisers ("RIAs") have dealt with significant regulatory, technological, and systemic change in recent years. Compared to FINRA-regulated entities, RIAs often face these...more

Troutman Pepper

SEC’s New Cyber Rules for Publicly Traded Companies — The Consumer Finance Podcast

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In this episode of The Consumer Finance Podcast, Chris Willis is joined by Kim Phan, a partner in our firm’s Privacy + Cyber practice, to discuss the Securities and Exchange Commission’s new cyber risk management and incident...more

Harris Beach PLLC

SEC Rulemaking 2023 - An Overview

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In 2023, the Securities and Exchange Commission (SEC) continued its trend of recent years of robust and significant rulemaking that affects the range of players in the securities industry — public companies, broker-dealers,...more

Dechert LLP

SEC Division of Examinations Releases 2024 Priorities

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The SEC’s Division of Examinations (EXAMS) published its report on 2024 Examination Priorities on October 16, 2023. The 2024 Examination Priorities continue to reflect an examination program that is vigorous and broad...more

Seward & Kissel LLP

SEC Issues Updated Fall 2023 Regulatory Agenda

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Who may be interested: Registered Investment Companies, Investment Advisers - Quick Take: The Office of Information and Regulatory Affairs, a division of the Office of Management and Budget, recently issued the Fall 2023...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - November 2023

...SEC Adopts Amendments to Fund Names Rule - On September 20, 2023, the U.S. Securities and Exchange Commission (SEC) adopted amendments to Rule 35d-1 under the Investment Company Act of 1940 (the Fund Names Rule) as well...more

Paul Hastings LLP

Public Company Watch: October 2023

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In the October edition of our Public Company Watch, we cover key issues impacting public companies, including the SEC adopting rules modernizing beneficial ownership reporting and short sale reporting, and issuing new C&DIs...more

Akin Gump Strauss Hauer & Feld LLP

SEC Releases Risk Alert on EXAMS Process

Investment Advisers: Assessing Risks, Scoping Examinations, and Requesting Documents* I. Introduction - The SEC-registered investment adviser (“adviser”) population is large and diverse, ranging from global asset managers...more

Morrison & Foerster LLP

Top 5 SEC Developments for July 2023

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important SEC enforcement developments from the past month, with links to primary resources. This...more

BakerHostetler

The SEC's Proposed Cybersecurity Rules: Regulatory Delay Does Not Bless Standing By

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The SEC’s Cybersecurity Proposals - The SEC has proposed four rules designed to address cybersecurity risk and management, including incident reporting by public companies....more

Pillsbury Winthrop Shaw Pittman LLP

The SEC’s Fast-Approaching Cybersecurity Overhaul for Public Companies and Regulated Entities

The SEC has nearly doubled the size of its Crypto Assets and Cyber Unit and has aggressively pursued cyber-related enforcement actions against public companies and regulated entities. In a few months the SEC will finalize...more

Morrison & Foerster LLP

Private Fund Advisers 2023 Regulatory Outlook

Sponsors and managers of private funds must attend to various routine regulatory and compliance tasks, which can include ongoing reporting obligations under the Investment Advisers Act of 1940 (the “Advisers Act”), updating...more

Dechert LLP

Dechert Cyber Bits - Special Edition: 2023 Predictions

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What is in store for Privacy and Cybersecurity in 2023 - As the year ends, we offer this special edition with predictions for 2023 from each member of the Cyber Bits Partner Committee. Regardless of what happens in 2023, we...more

Alston & Bird

SEC Reopening Comments After Technical Issues

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The Securities and Exchange Commission has reopened comments for nearly two dozen proposed rules and other matters. Our Securities Group details the list that includes some controversial rules about cybersecurity, SPACs, and...more

Wilson Sonsini Goodrich & Rosati

SEC Reopens Comment Periods for Certain Rulemaking Releases

On October 7, 2022, the U.S. Securities and Exchange Commission (SEC) announced that it will reopen the public comment periods for 11 rulemaking releases and one request for comment due to a technological error that resulted...more

Moore & Van Allen PLLC

The Devil Really is in the Details: The SEC Proposed Rule on Cybersecurity Risk Management for Investment Advisors, Registered...

Late last month the Securities and Exchange Commission (“SEC”) charged JP Morgan, UBS and Trade Station with violations of Regulation S-ID based on a range of  inadequacies in their identity theft red flag policies and...more

Foley Hoag LLP - Public Companies & the Law

SEC’s Expansion of Crypto Assets and Cyber Unit Signals Increased Enforcement Ahead

In a move that further executes upon the SEC’s increasingly tough rhetoric on cryptocurrency and cybersecurity, SEC Enforcement recently announced that it will nearly double the size of its newly-renamed Crypto Assets and...more

Mintz - Privacy & Cybersecurity Viewpoints

SEC Proposes New Cybersecurity Rules for Public Companies

Following closely on its proposal for substantial new cybersecurity requirements for investment advisers and registered investment companies, the Securities and Exchange Commission (SEC) unveiled a new slate of proposed...more

Ballard Spahr LLP

New SEC Proposed Cyber Rules Signal Concern About Systemic Risk

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After many years of signaling potential expansion of cybersecurity rules, the Securities and Exchange Commission (SEC) has issued in the past month two new sets of proposed rules governing cybersecurity.  The more recent set...more

Wilson Sonsini Goodrich & Rosati

SEC Proposes New Cybersecurity Reporting and Enhanced Standardized Disclosure

On March 9, 2022, the U.S. Securities and Exchange Commission (SEC) proposed new rules that would require current and periodic reporting of material cybersecurity incidents as well as more detailed disclosure of cybersecurity...more

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