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While this new final rule takes effect Aug. 2, the compliance dates are February 2026 for larger entities and August 2026 for smaller ones
"My reservations stem from the breadth of the rule and the likelihood that it will spawn more consumer notices than are helpful"
"The final amendments do not require a financial institution to enter into a contract with its service providers to deliver data breach notices .... This ...
Amended Reg S-P would require the customer notice of a breach that would have to be “in writing,” either on paper or electronically
The enforcement action yet again offers the lesson learned to continually check the veracity of your automated processes and to scrutinize the work of your ...
"Under these amendments, covered firms will be required to notify customers of breaches that might put their personal data at risk"
In the new legal cases targeting advisers, the SEC cited their responsibilities under Advisers Act section 204 (reports by IAs) and the books and records ...
While the exam did ask about due diligence of third-party vendors, Patel contends the exam team went too far in inquiring whether the adviser tracks ...
This P&P comes courtesy of SEC Compliance Consultants
The SEC’s Division of Examinations third risk alert of the year reminds advisers to include their branch offices in their compliance P&Ps, especially those designed ...