On May 16, 2024, the U.S. Securities and Exchange Commission announced the adoption of amendments to Regulation S-P that were proposed last year. The Final Amendments impose enhanced requirements on registered investment advisers, investment companies, broker dealers and transfer agents with respect to handling of consumer financial information.

Read the full client alert here.

Posted in Data Privacy Laws, Legislation, Privacy Law, SEC
Tags: asset management, broker dealers, private equity, registered investment advisers, Regulation S-P, rule amendments, transfer agents, U.S. Securities and Exchange Commission (“SEC”)
Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of Leslie Shanklin Leslie Shanklin

Leslie Shanklin is a partner in the Corporate Department, co-head of the Privacy & Cybersecurity Group and a member of the of the Technology, Media & Telecommunications group.

Leslie’s practice focuses on privacy and data security, delivering comprehensive expertise around data-related risk and…

Leslie Shanklin is a partner in the Corporate Department, co-head of the Privacy & Cybersecurity Group and a member of the of the Technology, Media & Telecommunications group.

Leslie’s practice focuses on privacy and data security, delivering comprehensive expertise around data-related risk and compliance. Leslie provides pragmatic, strategic and tech-savvy legal counsel to clients seeking to realize the essential value of data to their businesses while effectively managing risk and preserving trust. Leslie draws from deep legal, practical and technical expertise gained from leading global privacy teams and operations for multinational companies.

Leslie’s experience includes advising on the legal and risk aspects of data strategy, building and operationalizing data protection compliance programs in all regions of the world, providing strategic legal counsel around data privacy and security issues in commercial transactions, advising on legal aspects of information security risk, compliance and incident response, and advising on federal, state and international regulatory enforcement actions.

Leslie advises clients with a global lens, helping clients craft nimble, risk-based, forward-looking approaches to data management in the rapidly-evolving US and international privacy and information security legal landscape, including:

  • Federal laws such as Section 5 of the FTC Act and FTC rules and guidance, COPPA, VPPA, TCPA, and HIPAA
  • State laws such as the California Consumer Privacy Act (CCPA including CPRA amendments) and the California Medical Information Act (CMIA), as well as various existing and evolving laws in other US states such as Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Iowa (ICDPA), Tennessee (TIPA), Indiana (ICDPA), Montana (MCDPA) and Washington (My Health My Data Act)
  • International law and guidance such as the EU General Data Protection Regulation (GDPR), the ePrivacy Directive, the UK Data Protection Act, Brazil’s General Data Protection Law (LGPD), and Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA)

Leslie is a Certified Information Privacy Professional in the United States (CIPP/US) and Europe (CIPP/E) with the International Association of Privacy Professionals (IAPP). She previously served as Co-Chair of the international Hybrid Broadcast Broadband Television (HbbTV) Association Privacy Task Force.

Prior to joining Proskauer, Leslie led global privacy teams for media and entertainment companies for over a decade and most recently served on the Privacy leadership team for Warner Bros. Discovery.

Read more about Leslie Shanklin
Show more Show less
Photo of Robert Sutton Robert Sutton

Robert is a partner of the Private Funds Group and a member of the Corporate Department. He is a seasoned practitioner with over 20 years of experience counseling managers and advisers of private funds on regulatory matters, as well as regulatory issues related…

Robert is a partner of the Private Funds Group and a member of the Corporate Department. He is a seasoned practitioner with over 20 years of experience counseling managers and advisers of private funds on regulatory matters, as well as regulatory issues related to the formation and operation of private equity, credit, real estate, infrastructure, hedge and other private funds.

Rob has a deep knowledge of the market practice of asset managers and in particular, as it relates to Advisers Act-related issues. From some of the largest and most sophisticated firms in the global asset management industry to start-ups and mid-sized firms, Rob’s experience includes a wide spectrum of funds and asset classes across their life cycles. Rob regularly advises on matters in connection with: U.S. investment adviser registration and regulation; Advisers Act and other U.S. securities law issues relating to the formation, marketing and offering of private funds; Identifying and managing conflicts of interest, and addressing related Advisers Act risks, SEC examinations, and exam readiness preparation; Design and implementation of investment adviser compliance policies and procedures; U.S. regulatory issues relating to purchases and sales of investment advisory businesses (minority stake and control stake transactions, buy-side and sell-side representations); Advisers Act and other U.S. regulatory issues relating to private fund restructurings and recapitalizations, strip sales, continuation fund formations and similar transactions; Advisers Act issues relating to the formation of SPACs by investment advisers; and, Investment Company Act status analyses of private fund structures, investment transaction structures and other non-registered investment company structures.

Rob has been recognized by his clients and peers for his extraordinary work, gaining various accolades including mentions in preeminent directories such as The Legal 500.  He is also very active within the private funds industry, contributing to numerous publications and collaborating on several speaking engagements.

Prior to joining Proskauer, Rob was a partner in the Investment Funds Group at Kirkland & Ellis.

Read more about Robert Sutton
Show more Show less
Related Posts
SEC Revisits Regulation S-P After Twenty Years of Innovation to Information Technology
April 4, 2023
Shining a Light on the Corporate Transparency Act: FinCEN’s Rules for Beneficial Ownership Reporting
January 18, 2023
SolarWinds: A Lesson on How Companies Victimized by Data Breaches Can Quickly Become the Target of Litigation and Regulatory Investigations
November 16, 2022