SEC Cybersecurity Exam Requests

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Cybersecurity seems to be all the rage with both SEC and state regulators. However, advisers have been flying blind as to what the regulators may actually request during a cybersecurity exam. Thanks to our contacts in the industry, we were able … Continued

Do You Have a Mobile Device Policy?

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With the proliferation of smart phones, iPads and table computers in the advisory business, I would suggest that all advisers probably would benefit from developing and implementing policies and procedures regarding their use. Here are some issues you should consider: … Continued

Alert – Cybersecurity

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Dear Compliance Professional, On April 15, 2014, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert as part of its 2014 initiative to assess Cybersecurity preparedness.  OCIE’s cybersecurity initiative is designed to assess cybersecurity preparedness in … Continued

Year-End Compliance Checklist

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Dear Compliance Professional, There are a few compliance actions that all investment advisers can benefit from undertaking at this time of year. Some obvious, some not so obvious. All important. So, without further ado, here is our end-of-the year checklist: … Continued

The SEC Speaks (and Speaks)

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Dear Compliance Professional, In recent weeks SEC officials have been quite chatty. What differentiates these recent pronouncements from the SEC’s usual speechifying is that the recent stuff contains a trove of useful compliance insights. This Compliance Newsletter summarizes what advisers … Continued

Identity Theft Red Flag Rules

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On April 10th, the Securities and Exchange Commission (“SEC”) and the Commodity Futures Trading Commission (“CFTC”) jointly approved a final rule requiring broker-dealers, mutual funds, federally registered investment advisers, and certain other regulated entities to adopt programs designed to detect … Continued

Massachusetts Data Privacy Act

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Please note by March 1, 2012, advisers must ensure their agreements with third-party service providers with which they share personal information meet Massachusetts Data Privacy Act (201 CMR 17) requirements. http://www.mass.gov/ocabr/docs/idtheft/201cmr1700reg.pdf

Compliance Alert! Data Security

posted in: Alert!, Privacy & Data Security | 0

Dear Compliance Professional, The protection of a client’s non-public personal information is one of the most important tasks entrusted to an investment adviser. Unfortunately, it is also one of the most vexing issues confronting compliance professionals. Any time an adviser … Continued