SEC Compliance

Consistent with the ongoing guidance/requirements from the SEC and FINRA, all firms must have and enforce data security policies and procedures.  Even the best policies and procedures may, however, not
Continue Reading A Data Breach! You Better Check The Law Of The States In Which You Have Customers

On Monday, September 12, 2016, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) announced that a “Supervision Initiative” will take place across the country.

OCIE staff will conduct focused
Continue Reading Why is Anyone Surprised with the SEC Examining Firms with Previously Disciplined Advisors?

The SEC recently created a new position associated with cybersecurity; senior adviser to the chair for cybersecurity (Christopher R. Hetner). Mr. Hetner has an extensive background in information technology and,
Continue Reading The SEC Now Has A Lead Cybersecurity Senior Adviser: Now What?