On September 20, 2022, the Securities and Exchange Commission (SEC) settled an enforcement action with a large, registered investment adviser (the Firm) for alleged violations of the Safeguards Rule and the Disposal Rule of Regulation S-P that arose in the context of a data disposal process, imposing a $35 million penalty. Specifically, the SEC […]
SEC Settles Enforcement Actions with Broker-Dealers and Investment Advisors for Identity Protection Deficiencies
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 theft, in violation of the SEC’s Identity Theft Red Flags Rule, or Regulation S-ID. Regulation S-ID requires registered financial institutions, broker dealers, and investment advisers […]
Maryland Amends Data Breach and Reasonable Security Requirements
Maryland recently passed House Bill 962, amending Maryland’s Personal Information Protection Act (PIPA) (Md. Code Ann. Comm. Law 14-3504). As summarized below, House Bill 962 amends certain aspects of PIPA relating to breach notification and maintaining reasonable security measures to protect personal information. The bill becomes effective October 1, 2022. Reasonable Security: Beginning October 1, […]
President Biden Issues Executive Order Directing Coordinated Federal Approach to Digital Assets
As a result of the rise in digital assets, President Biden signed an Executive Order on March 9, 2022 ordering a review of the nation’s approach to cryptocurrency. The Executive Order on Ensuring Responsible Development of Digital Assets (the “Order”) contains both broad policy objectives and specific analysis to be conducted by the federal government. […]
SEC Proposed Rule Will Require Private Funds to Report Certain Cyber Events
On January 26, 2022, the U.S. Securities and Exchange Commission (SEC) proposed new rules to enhance hedge fund and private fund disclosure requirements and increase regulators’ visibility into the private funds industry. The proposed rules would amend the SEC’s Form PF, the confidential reporting form by which private funds disclose regulatory assets to the SEC, […]