SEC Risk Alert Highlighting Investment Adviser and Broker-Dealer Compliance Issues Related to Regulation S-P
On April 16, 2019, the Office of Compliance Inspections and Examinations (“OCIE”) of the U.S. Securities and Exchange Commission (“SEC”) issued a Risk Alert (the “Risk Alert”) highlighting OCIE’s observations of common compliance issues relating to Regulation S-P (“Reg S-P”). Reg S-P is the primary SEC rule governing the privacy notices and privacy protection policies of registered investment advisers and broker-dealers (“Registrants”). This Risk Alert follows multiple SEC cybersecurity initiatives aimed at assessing Registrant cybersecurity preparedness. This memorandum is a summary of the Reg S-P compliance issues identified in the Risk Alert and some key takeaways for Registrants.