UpFront » April 2019

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…