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Best practices include adding language to your terms of employment that prohibits a departing employee from taking sensitive client data; having departing employees sign an ...
After the initial privacy notice, another one is unnecessary unless these changes occur
The Commodity Futures Trading Commission (“CFTC” or “Commission”) is adopting amendments to revise its regulations requiring covered persons to provide annual privacy notices to customers. ...
Through sharing some of the Regulation S-P compliance issues it observed, OCIE encourages registrants to review their written policies and procedures, including implementation of those ...
With cybersecurity as hot as a black hole, it’s no surprise that OCIE wants advisers to take a new look at their cybersecurity P&Ps as ...
OCIE chalked up more than 2,000 IA exams in FY 2018, visiting 17% of all firms. These numbers may be out of reach in FY ...
The Golden State takes pleasure in being the first in the nation at things and this record continues after the state has passed the country’s ...
Better late than never. Three years after the SEC amended its privacy rules eliminating the requirement to send customers an annual notice if nothing has ...
The Commodity Futures Trading Commission (“CFTC” or “Commission”) is proposing to revise its regulations requiring covered persons to provide annual privacy notices to customers. The ...
ITG did not adequately limit access to GATE, a firm system containing all order flow routed through ITG, including open child-level POSIT order information for ...