New Risk Alert on Regulation S-P

Last week the Office of Compliance Inspections and Examinations (“OCIE”) released a Risk Alert (the “Alert”) on Regulation S-P, the Privacy Rule. The Alert described the most common deficiencies found regarding the Privacy Rule over the past two years of examinations of both registered investment advisers and broker-dealers. The top findings included: Failure to deliver an initial notice, annual notice and/or opt-out notice Lack of written policies and procedures that addressed all requirements of the…

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