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In the new legal cases targeting advisers, the SEC cited their responsibilities under Advisers Act section 204 (reports by IAs) and the books and records ...
While the exam did ask about due diligence of third-party vendors, Patel contends the exam team went too far in inquiring whether the adviser tracks ...
This P&P comes courtesy of SEC Compliance Consultants
The SEC’s Division of Examinations third risk alert of the year reminds advisers to include their branch offices in their compliance P&Ps, especially those designed ...
Firms should consider their entire organization, including branch offices, when implementing written policies and procedures for the safeguarding of customer records and information to ensure ...
This new proposal from the SEC would revise Reg S-P to require IAs, ICs and B-Ds to "adopt written policies and procedures for incident response ...
The letter focuses on e-communications and sheds more light onto authorities’ interest in firms’ use of new communications platforms
Sources assert this is an SEC enforcement letter that went to a broker-dealer in the agency's investigation of the business use of e-commmunications channels
Eliminating sensitive computer data can be as stubborn as a tempestuous two-year-old. But failing to do so, can come with a high cost
The current Reg S-P requires firms to alert customers how they will use their information. The SEC proposed amending Reg S-P in 2008 but it ...