Proskauer on Privacy

Results from the SEC’s First Round of Cybersecurity Examinations. On February 3, 2015, the OCIE published a risk alert summarizing its findings from its examinations of over 100 registered investment advisers and broker-dealers. The examinations were conducted as part of the OCIE’s cybersecurity examination initiative, announced in April 2014, to assess cybersecurity preparedness in the … Continue Reading

Article 29 Working Party Issues Statement Following Landmark CJEU Safe Harbor Ruling

By Proskauer on Privacy on October 16, 2015 Posted in Data Privacy Laws

Since the Article 29 Working Party on the Protection of Individuals (“WP29”) announced last week that it would it shortly issue a statement on the landmark CJEU ruling invalidating the Safe Harbor Decision (Schrems v. Data Protection Commissioner (C-362- 14)), we have been awaiting their guidance. Today, the WP29 issued an important statement offering some … Continue Reading

SEC Announces Cybersecurity Enforcement Action

By Proskauer on Privacy on September 24, 2015 Posted in Cybersecurity

On September 22, 2015, the Securities and Exchange Commission (SEC) announced the settlement of an enforcement action against a St. Louis-based registered investment adviser (Adviser) brought under Rule 30(a) of Regulation S-P (Safeguards Rule). The SEC Order charged the Adviser with violating the Safeguards Rule by failing to adopt written cybersecurity policies and procedures reasonably designed to … Continue Reading

SEC to Conduct Second Round of Cybersecurity Examinations

By Proskauer on Privacy on September 16, 2015 Posted in Cybersecurity

On September 15, 2015, the Office of Compliance Inspections and Examinations (OCIE) of the Securities and Exchange Commission (SEC) issued a Risk Alert announcing its second round of examinations of registered investment advisers and broker-dealers under its cybersecurity examination initiative.… Continue Reading