SEC distributes Risk Alert related to Regulation S-P – Privacy Notices and Safeguard Policies
By Lauri B. London
Regulation S-P requires IAs and BDs to safeguard customer personally identifiable information (“PII”), to have policies and procedures regarding the sharing and protection of PII, to inform clients of such policies and procedures, and to provide customers an “opt-out” with respect to certain sharing of PII.
The SEC recently issued a Risk Alert with examples of common deficiencies observed by OCIE, which creates an excellent road map for compliance with Regulation S-P as OCIE seemed to observe deficiencies with each element of the Regulation.
Advisers should review the attached Risk Alert and use it to examine their own policies and procedures with respect to Regulation S-P, and the implementation of their policies and procedures, beginning with distributing privacy notices when the client relationship is first established. Cohen & Buckmann can provide Investment Advisers with compliance advice on regulatory requirements, including Regulation S-P.