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SEC Enforcement: Where do we come from? Where are we going?

In Dan Brown’s latest best-seller, “Origin,” he explores the questions: (1) Where do we come from (meaning, how did life get formed)? and (2) Where are we going (or, how will we evolve)? While the US Securities and Exchange Commission (SEC) Division of Enforcement’s “Annual Report, A Look Back at 2017” is no “Origin,” “The Da Vinci Code” or even...

Is Your Firm Cyber Secure?

Eversheds Sutherland Partner Brian Rubin is quoted in this Financial Advisor article regarding the US Securities and Exchange Commission’s creation of its Cyber Unit and how broker-dealers and investment advisors should be on high alert. “I’m aware of exams that are going on by both the SEC and FINRA, and I think it’s just a matter of time before enforcement referrals are made,” said...

SEC and States Are Upping Their Cyber Game, Are You Doing the Same?

With the creation of the Cyber Unit, the SEC is beefing up its technical expertise and demonstrating that it too will evolve and adapt as cybersecurity threats become more advanced. The agency is making it increasingly clear that it expects those it regulates to up their games as well. The unit will function as part of the SEC’s Enforcement Division to target misconduct along six...

Regulators’ Cybersecurity Crackdown Already in Full Swing. Are Firms Ready?

Eversheds Sutherland’s legal alert, SEC and States Are Upping Their Cyber Game, Are You Doing the Same?, is mentioned in this Financial Advisor article. “I’m aware of exams that are going on by both the SEC and FINRA, and I think it’s just a matter of time before enforcement referrals are made,” said Brian Rubin, partner and co-author of the legal...

The Final Rule: DOL Proposes to Extend Transition Period until July 1, 2019, and Issues Additional Non-Enforcement Policy for Arbitration Limitations

By a notice published in the Federal Register on August 31, 2017, the Department of Labor proposed to extend from January 1, 2018, until July 1, 2019, the date for compliance with the full conditions in its new “investment advice” fiduciary definition and related exemptions, which became generally applicable on June 9. Learn...

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