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Investment Adviser Enforcement Actions Cybersecurity

SEC Compliance Consultants, Inc. (SEC³)

Regulatory Roundup for July 2024

SEC Loses in ALJ Case, DOL’s Latest Fiduciary Rule Put on Hold, and SEC Reconsiders AI and Custody Rule Proposals - Welcome to our July Regulatory Roundup, where we provide a quick look at the latest regulatory developments....more

Faegre Drinker Biddle & Reath LLP

FINRA to Member Firms: “You Heard the SEC, Create Plans for Data Breaches Now!”

On May 15, 2024, the SEC announced it would make amendments to Regulation S-P (Reg S-P). This will be the first amendment to the regulation since its adoption 24 years ago in 2000. The regulation focuses on how institutions...more

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

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

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

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

Seward & Kissel LLP

SEC Announces Robust Fiscal Year 2023 Enforcement Results

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Who may be interested: Registered Investment Companies; Directors of Registered Investment Companies; and Investment Advisers - Quick Take: The SEC’s Division of Enforcement (Enforcement) released a report summarizing its...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

K&L Gates LLP

The SEC Publishes 2024 Examination Priorities Ahead of Schedule, Previewing Key Areas of Focus for Registered Entities

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On 16 October 2023, the Division of Examinations (Division) of the US Securities and Exchange Commission (SEC) released its examination priorities for the 2024 fiscal year (the Report). The Division released this Report...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

Morgan Lewis

Current Developments in Sec and Finra Examinations & Enforcement 2022–2023 - A Special Report for Investment Advisers and...

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Registered entities continued to be a significant focus of the US Securities and Exchange Commission’s (SEC’s or Commission’s) enforcement and rulemaking programs in 2022, and we expect similar attention this year. The SEC’s...more

A&O Shearman

2023 Report on FINRA’s Examination and Risk Monitoring Program

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On January 10, 2023, the Financial Industry Regulatory Authority (“FINRA”) issued its 2023 Report on FINRA’s Examination and Risk Monitoring Program (the “Report”). The Report, which is a more comprehensive version of FINRA’s...more

Katten Muchin Rosenman LLP

Financial Markets and Funds Quick Take | Issue 8

SEC Advertising Rules – Client Resource Center - November 4 was the compliance date for the new rule governing advertising and solicitation activities by investment advisers. The new rule substantially revises decades old...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - August 2022

The investment management industry faces a range of proposed new SEC regulations, including ESG and fund name rules, and the agency is seeking comments that could lead to other new rules. Also, a reminder of approaching...more

Alston & Bird

SEC Settles Enforcement Actions with Broker-Dealers and Investment Advisors for Identity Protection Deficiencies

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On July 27, 2022, the Securities and Exchange Commission (SEC) separately settled three enforcement actions with broker-dealers and investment advisers for alleged deficiencies relating to the prevention of customer identity...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

Pillsbury Winthrop Shaw Pittman LLP

Twelve Hours to Get It Right: The SEC Intensifies Its Focus on Cybersecurity

The SEC’s recent enforcement actions, public statements and proposed rulemaking indicate that cybersecurity will be an area of heightened focus for the Gensler Commission. New proposed rules would require public companies...more

Holland & Knight LLP

SEC Proposes Substantial New Cybersecurity Requirements for Investment Advisers and Companies

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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

Holland & Knight LLP

SEC Chair Gensler Remarks Indicate 2022 Action Expanding Cyber Requirements

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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

Balch & Bingham LLP

SEC Issues Cybersecurity Sanctions Against Eight Firms

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Background - On August 30, 2021, the Securities and Exchange Commission (SEC) sanctioned eight firms in three actions for cybersecurity failures in their policies and procedures that exposed the personal information of...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

Kramer Levin Naftalis & Frankel LLP

SEC Continues Focus on Cybersecurity in Three New Actions Targeting Investment Advisers and Broker Dealers

Demonstrating its continued focus on cybersecurity enforcement, the Securities and Exchange Commission (SEC) announced three new actions on Aug. 30 charging eight firms with maintaining deficient cybersecurity policies and...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Heightens Focus on Cybersecurity

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

King & Spalding

SEC Returns Spotlight to Cybersecurity Disclosure Enforcement

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On June 15, the Securities and Exchange Commission announced a settlement with First American Financial Corporation for what the SEC found were inadequate disclosure controls and procedural violations, revealed in connection...more

King & Spalding

Widening the Aperture Beyond Retail-Focused Advisers

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SEC Enforcement and Exams Likely to Focus More on Private Funds in the New Administration - For the next several weeks and months, intense focus will be trained on determining the priorities of the Biden administration. We...more

WilmerHale

SEC Refreshes Regulation S-K’s Financial Information Requirements

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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

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