A Third Party's Perspective on Third Party Risk
Why Time Matters: Partners Lindsay Gerdes and Michael J. Bronson on Swift Action in Government Investigations
Consumer Finance Monitor Podcast Episode: Why do Fintechs Want to Become Banks?
Privacy Issues from Third-Party Website Tags
What's the Tea in L&E? Employee Devices: What is #NSFW?
Episode 331- NAVEX State of Risk and Compliance Programs
What the Board Should Be Asking About the Compliance Program
Video: Artificial Intelligence Use in Political Campaigns
Episode 329 -- Bryn Sedlacek from Aravo on TPRM Holistic Risks and Unified Visibility
Compliance Lessons from Dating in Your 50s
The Justice Insiders Podcast - AI-Washing: Everything Old Is New Again
The AI Shakeup: New Tech Innovations and the Future of Corporate Law
Principled Podcast: S11E7 | Fortifying Ethical Frameworks: Navigating Emerging Risks in the Middle East
Managing Compliance Risk for Human Trafficking and Modern Slavery
Common Scenarios Triggering False Claims Act Violations, Part 3: Claims and Investigations
Navigating Bank-Fintech Partnerships: Avoiding Common Pitfalls — The Consumer Finance Podcast
Episode 326 -- Dottie Schindlinger on Diligent's Report on Board Oversight of Cybersecurity Risks and Performance
Revisiting Financial Institution Incentive Compensation Rules Under Dodd-Frank — The Consumer Finance Podcast
Episode 325 -- AI and Emerging Compliance Frameworks
AI Risks for Government Contractors: Navigating Disputes and Litigation
The Office of Information and Regulatory Affairs, a division of the Office of Management and Budget, released its Spring 2024 Unified Agenda of Regulatory and Deregulatory Actions, which includes short- and long-term...more
On May 13, 2024, FinCEN and the SEC jointly proposed a new rule that would require SEC-registered investment advisers and exempt reporting advisers to maintain written customer identification programs (CIPs). The new rule...more
As a reminder, each registered investment adviser must file an annual updating amendment to its Form ADV within 90 days of its fiscal year end. This means an adviser with a December 31 fiscal year end will be required to file...more
In 2023, the Securities and Exchange Commission issued various proposed rules on regulatory changes that will affect SEC-registered investment advisers (RIAs). Since these rules are likely to be put into effect, RIAs should...more
Since the 2008 financial crisis, the SEC has made repeated encroachments into the private funds industry. Registered investment advisers (RIAs) have borne the heaviest regulatory burden: routine examinations, frequent...more
According to its Spring 2023 rulemaking agenda, the U.S. Securities and Exchange Commission (SEC) has delayed issuance of two sets of cybersecurity requirements that previously were expected to be finalized in April 2023. The...more
Based on updates to its rulemaking agenda that were released last week, the U.S. Securities and Exchange Commission (SEC) has delayed approval of two cybersecurity rules until at least October 2023. Both proposed rules were...more
SEC Rules and Amendments - Liquidity Rule Amendments: Interval Funds to the Rescue? On November 2, 2022, the Securities and Exchange Commission (SEC) voted to propose significant amendments to Rule 22e-4 under the...more
In 2023, Registered Investment Advisers (“RIAs”) who are registered with the Securities and Exchange Commission (“SEC”) should be prepared for regulatory changes. These include proposed changes to rules governing RIA...more
On 9 February 2022, the U.S. Securities and Exchange Commission (the SEC) proposed new rules and amendments to existing rules (together, the Proposed Rules) addressing cybersecurity risk management under the Investment...more
In today’s asset management landscape, cybersecurity threats are omnipresent, and with constantly evolving tools of attack, actual breaches have become increasingly prevalent. As the complexity, scope, and frequency of cyber...more
SEC Proposes and Seeks Comments on New Cybersecurity Rules - At an open meeting on February 9, 2022, the Securities and Exchange Commission (“SEC”) voted three-to-one to propose new and amended rules regarding cybersecurity...more
At an open meeting on February 9, 2022, the Securities and Exchange Commission voted three-to-one to propose new and amended rules regarding cybersecurity risk management, cyber incident reporting and cyber risk disclosure...more
In the latest move by a regulator aimed at bolstering cyber defenses, on February 9, 2022, the U.S. Securities and Exchange Commission voted to propose new rules to address the cybersecurity risks faced by registered...more
On Wednesday, the Securities and Exchange Commission announced proposed new cybersecurity risk management rules and amendments for investment advisers and investment companies. The proposed rules are designed to address...more
On February 9, 2022, the U.S. Securities and Exchange Commission (SEC) voted to propose cybersecurity rules applicable to investment advisers and registered investment companies, including business development companies. If...more
In this Issue. The Office of the Comptroller of the Currency (OCC) is seeking feedback on principles for climate-related financial risk management for large banks; the Department of Justice’s Antitrust Division is seeking...more
In This Issue. The federal bank regulatory agencies requested public comment on proposed guidance designed to help banking organizations manage risks associated with third-party relationships; the Office of the Comptroller of...more
Compliance is a key issue for all firms. Many companies use the U.S. sentencing guidelines as a starting point. In other instances, regulators craft a starting point with rules that direct the creation of programs....more
In light of COVID-19, the U.S. Securities and Exchange Commission ("SEC"), recognizing that RIA Firms are facing operational, technological, commercial and other issues, has also outlined "regulatory and compliance questions...more
We recently discussed the topic of risk management as it relates to artificial intelligence (AI) in financial services, and suggested certain tips for the financial services sector. This article is the first of a series that...more
As public concern over data security grows in the wake of the Equifax data breach, the U.S. Securities and Exchange Commission (SEC) is increasing its scrutiny of registered investment advisors (RIAs). In turn, RIAs should...more
On December 11, 2015, the Securities and Exchange Commission (SEC) voted to propose a new rule (the Proposed Rule) that significantly modifies the regulation of the use of derivatives by registered investment companies,...more
The SEC prevailed on two summary judgment motions. One centered on a manipulation action. The other was against an attorney who facilitated a prime bank fraud. The Commission also filed: An action against UBS tied to its...more
Non-Enforcement Cybersecurity Is At the Top of SEC Examination Concerns In a recent SEC “risk alert” for registered broker-dealers and investment advisers, the SEC’s Office of Compliance Inspections and Examinations (OCIE)...more