On April 16, 2019, the Securities and Exchange Commission’s Office of Compliance, Inspections and Examinations (SEC OCIE) issued a helpful Risk Alert relating to the privacy Regulation S-P (Reg S-P) and “Safeguards Rule” policies and procedures of registered investment advisers and broker dealers. The Risk Alert gives registered investment advisers and broker-dealers fair notice of various points of emphasis the SEC OCIE considers important from an examination perspective and those points that could surface post-breach when the SEC OCIE’s antennae are well-tuned towards finding fault with the registrant’s data protection practices.

After recounting the basics of Reg S-P’s privacy requirements and the requirements of the Safeguards Rule, the SEC OCIE lists what it calls “examples” of the “most common deficiencies or weaknesses identified by OCIE staff in connection with the Safeguards Rule.”

Click here for the full GT Alert.