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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
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
On May 16, 2024, the U.S. Securities and Exchange Commission (“SEC”) announced the adoption of amendments to Regulation S-P that were proposed last year (“Final Amendments”).[1] The Final Amendments impose enhanced...more
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
Welcome to the third edition of our AI Legal News Summer Roundup! After five class actions were filed between June 28 and July 11 (as reported on in our first edition of this series), on July 21, another class action lawsuit...more
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
As a number of recent headlines demonstrate, the U.S. Securities and Exchange Commission (SEC) and other regulators have fined and penalized employers and employees in the financial services industry for non-compliance with...more
The SEC Division of Examinations recently published a risk alert summarizing observations from exams of registered investment advisers and broker-dealers related to compliance with Reg. S-ID, which is generally designed to...more
On September 20, 2022, the Securities and Exchange Commission (SEC) settled an enforcement action with a large, registered investment adviser (the Firm) for alleged violations of the Safeguards Rule and the Disposal Rule of...more
In This Issue: ..The Consumer Financial Protection Bureau (CFPB) published a Consumer Financial Protection Circular 2022-04 (Circular) in relation to safeguarding consumer data under the Consumer Financial Protection Act...more
The SEC Division of Examinations recently released its 2022 Division of Examinations “Priorities.” The 2022 Priorities provide critical insight into what the Division of Examinations (the “Division”) considers the most...more
Welcome to this month's issue of The BR Privacy & Security Download, the digital newsletter of Blank Rome’s Privacy, Security & Data Protection practice. ...more
Following U.S. Securities and Exchange Commission (SEC) Chairman Gary Gensler's recent speech directing the agency to expand cybersecurity requirements on regulated entities, the SEC on Feb. 9, 2022, voted to propose new...more
U.S. Securities and Exchange Commission (SEC) Chair Gary Gensler made remarks on Jan. 24, 2022, at Northwestern University Pritzker School of Law's Annual Securities Regulation Institute regarding the SEC's work to improve...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 three settled orders against several investment advisers, broker-dealers, and dual registrants for violations of Regulation S-P allegedly resulting...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
THE SITUATION: In recent years, cryptocurrency has presented an exciting opportunity to invest in a new asset class—at the cost of accepting certain risks. Unlike traditional financial assets, cryptocurrency has lacked...more
The SEC continued its recent run of rulemaking activity with two sets of amendments last week that impact reporting by public companies. On Tuesday, November 17, the SEC announced that it will begin to permit the use of...more
The Risk Alert makes clear that OCIE has observed an increase in the frequency of credential stuffing attacks against Registrants, including some successful credential stuffing attacks that resulted in the loss of customer...more
On January 27, 2020, OCIE issued a report detailing cybersecurity and resiliency observations the staff made after "thousands of examinations of broker-dealers, investment advisers, clearing agencies, national securities...more
On January 27, 2020, the SEC’s Office of Compliance Inspections and Examinations (OCIE) announced its most recent Cybersecurity and Resiliency Observations. This report highlights specific practices that have been, and can be...more
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
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
The SEC recently issued a risk alert warning about using vendors and cloud-based platforms. Many broker dealers and investment advisors are turning to these third parties to store customer data. In its alert, the SEC’s Office...more