Covered institutions like SEC-registered investment advisors will be required to create an incident response program as part of their written policies and procedures. This program must be reasonably designed to detect, respond to, and recover from unauthorized access to or use of customer information.
Earlier this month, the SEC announced proposed amendments to Regulation S-P that would enhance the protection of customer information by requiring that investment advisers (as well as broker-dealers, investment companies,…
The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) has issued a risk alert relating to Regulation S-P, which requires SEC registered investment advisors to, among other things, provide privacy notices to their customers and adopt written safeguarding policies and procedures to safeguard customer information.