CCPA Enforcement Begins July 1 – Are You Ready?

Jun 5, 2020 10:30:00 AM

There are many aspects to compliance and from time to time, I like to bring in complementary experts to share their perspectives and knowledge. This week, I’m delighted to have Michael Williams from Clym (pronounced like “climb”) tell you more about data privacy on your website and an important new regulation from California that can affect any firm in the country. I hope you enjoy this post. Afte...

Cybersecurity: A Question of When, Not If, Your Company will Fall Victim

Feb 20, 2020 1:30:00 PM

Financial firms, including broker-dealers and registered investment advisers, are at a high risk of cybersecurity attacks primarily because they control both their own data and the sensitive data related to clients. In an effort to educate broker-dealers about the cyber-best practices, FINRA published their Report on Selected  Cybersecurity Practices - 2018 in December 2018.  In this report, FINRA...

Overhaul Your Privacy Policy, Part 2: Elements of a good privacy policy

Jan 24, 2020 1:00:00 PM

Like most legal documents, privacy policies are fairly bland , and, let’s be honest, few people read them. But the recent enactment of the California Consumer Protection Act (“CCPA”) has Joot fielding privacy policy questions from clients and service providers alike. In our previous post - Is it time to overhaul your privacy policy and notice? - we discussed whether your firm must comply with the ...

Is it time to overhaul your privacy policy and notice?

Jan 10, 2020 10:45:00 AM

California recently passed amendments to the California Consumer Protection Act (“CCPA”), which took effect on January 1, 2020! Under the CCPA, investment advisers that are located in or have clients in California may need to update their privacy policy and notices to comply with the new law. For a deeper discussion of the new law, I recommend Morgan Lewis’ LawFlash updates from July and September...

Tips for a More Secure Client Relationship: A Commentary on OCIE's Risk Alert on Privacy and Data Protection

May 9, 2019 11:00:00 AM

The SEC’s Office of Compliance Inspections and Examinations (colloquially known as “OCIE” or just the “SEC” to many market participants) recently issued another risk alert. The topic this time was privacy policies under Regulation S-P. Below are examples of the most common deficiencies or weaknesses identified by OCIE staff in connection with the Safeguard Rule. If you have any questions about the...

GDPR in a Nutshell and the Titan Platform*

Sep 21, 2018 8:30:07 AM

* The information in this article is provided for informational purposes only.  No information should be construed as legal advice from Advanced Alternative Investment Systems or the Titan Technology Group, Ltd. or the individual author nor is it intended to be a substitute for legal counsel. Introduction General Data Protection Regulation (“GDPR”) falls under the European Union’s data privacy and...