We urge our clients to consult Pillsbury’s comprehensive COVID-19 Resource Center for information regarding Responding to a Global Crisis, Business Interruption, Cybersecurity, Employer Concerns and other general matters related to the COVID-19 pandemic. We also recommend the following specific measures to mitigate risks of business interruption and regulatory noncompliance resulting…
SEC Risk Alert regarding safety of customer records and cloud vendor diligence. As part of its cybersecurity sweep, the SEC has examined risks related to the storage of customer records and information by investment advisers on cloud-based storage platforms and issued a Risk Alert, “Safeguarding Customer Records and Information in Network…
In a press release issued by the Securities and Exchange Commission on December 20, 2018, the SEC’s Office of Compliance Inspections and Examinations (OCIE) announced its 2019 Examination Priorities. This year’s examination priorities, although not exhaustive, are divided into 6 categories: Compliance and risk at registrants responsible for critical market…
Covered businesses will need to update policies and procedures for responding to customer inquiries about collection, use, sale and disclosure of customers’ personal information or face stiff enforcement actions. Takeaways The California Consumer Privacy Act of 2018 provides consumers with broad rights to control use of their personal information by…
This alert contains a summary of the primary annual and periodic compliance-related obligations that may apply to investment advisers registered with the Securities and Exchange Commission (the “SEC”) or with a particular state (“Investment Advisers”), and commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”) registered with the Commodity Futures…
The following are some of the important annual compliance obligations investment advisers either registered with the Securities and Exchange Commission (the “SEC”) or with a particular state (“Investment Adviser”) and commodity pool operators (“CPOs”) or commodity trading advisors (“CTAs”) registered with the Commodity Futures Trading Commission (the “CFTC”) should be…
The ERISA Advisory Council recently announced that, as part of its goals for 2016, it will be focusing on cybersecurity issues affecting retirement plans and, in particular, the extent to which such issues relate to third-party administrators and vendors (TPAs) of retirement plans. By shining the spotlight on the role…
At the end of this month, the annual updating amendments for investment advisers’ Form ADV will be due. The following are some of the important annual compliance obligations investment advisers either registered with the Securities and Exchange Commission (the “SEC”) or with a particular state (“Investment Adviser”) and commodity pool…
Investment managers, particularly high priority cybercrime targets, such as hedge funds and quantitative strategy managers, are encouraged to consider the government-industry information sharing option and liability protection afforded by the new legislation. For more information, please contact the Investment Fund and Investment Management group. On Tuesday, October 27, the U.S.…
Brian Finch, a partner in Pillsbury’s Government Law & Strategies Practice, will be speaking on cybersecurity at a 100WHF event in San Francisco on October 13, 2015. The event is titled Under Attack: Cyberdefense in the Network Age. Mr. Finch is recognized as a leading legal authority on matters related to…