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SEC Moves to Update Transfer Agent Rules; New Rules Likely to Impact Unclaimed Property and Cybersecurity

On December 22, 2015, the Securities and Exchange Commission took the first step in overhauling SEC regulation of transfer agents, the little-discussed but critical intermediaries involved in the prompt clearance and settlement of almost all U.S. securities. After many years in which other types of financial market intermediaries took center stage on the SEC’s rulemaking agenda, the...

They’re Baaaack . . . SECs Office of Compliance Inspections and Examinations Releases New Cybersecurity Risk Alert

Yesterday, the U.S. Securities and Exchange Commission (SEC) Office of Compliance Inspections and Examinations (OCIE) released a Risk Alert describing OCIE’s 2015 cybersecurity exam initiative.  [link to www.sec.gov/ocie/announcement/ocie-2015-cybersecurity-examination-initiative.pdf].  As the Risk Alert notes, OCIE’s new cybersecurity initiative builds on information OCIE learned from...

Sutherland and the Financial Services Institute Complete Benchmarking Survey on Cybersecurity Practices

WASHINGTON—Sutherland Asbill & Brennan LLP and the Financial Services Institute (FSI) have completed a survey of FSI members concerning cybersecurity issues. The survey included responses from 39 broker-dealers (92% of which were dually registered as investment advisers), ranging in size from fewer than 100 registered representatives to more than 2,000. The survey covered a variety...

Sutherland Conducts Extensive Cybersecurity Survey of Broker-dealers

Sutherland attorneys Brian Rubin and Charlie Kruly, along with the Financial Services Institute (FSI), the trade association for independent contractor broker-dealers, recently conducted a survey of the cybersecurity practices of FSI members.  The survey covered many aspects of cybersecurity governance, including vendor management, technical safeguards, and cybersecurity policies and...

Managing a Cyberattack: An Interactive Simulation at the ACC Advanced Compliance Education Summit

It is 3:00 in the morning and your children are safe in bed, but the phone is ringing at the FBI! Sutherland’s Mark Thibodeaux; Cyndi Baily, Chief Compliance Officer at Alere Toxicology; Sarah Sandstorm, Contracts Counsel at KBM Group; and Special Agent Corey Harris from the FBI presented an interactive simulation of a cyber-attack at the ACC’s Advanced Compliance Education Summit...

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