Lessons Learned from Recent Cybersecurity SEC Enforcement Action


Cybersecurity SEC Enforcement Action On 9/26/2018 the Securities and Exchange Commission charged Voya Financial Advisors, Inc. (‘VFA”), with violating the Safeguards Rule and the Identity Theft Red Flags Rule, which are designed to protect confidential customer information and protect customers from the risk of identity theft. The SEC’s Order states...

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Is Cannabis Making You Paranoid?

cannabis investing

Why, who’s asking? Many cannabis-related businesses are in need of assistance with their fundraising efforts to expand their operations. Therefore, broker-dealers ask our Consultants more and more whether they can safely provide investment services to prospective customers in the cannabis industry. We understand that as the industry grows (like a...

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Tone-Deaf at the Top

tone deaf

I recently spoke at the IA Watch/Regulatory Compliance Watch compliance conference in Philadelphia sponsored by Simplify Compliance, where the discussion turned to firms’ tone at the top. “Tone at the Top” is a term that describes a firm’s management and whether they are committed to ethical behavior, honesty, and integrity....

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Regulatory Exams – Setting the Tone and Putting Your Best Foot Forward

best foot forward

The SEC’s 2018 National Exam Priorities[i] clearly lays out five principals guiding the Office of Compliance Inspections and Examinations (OCIE).  Three of those five are centered heavily around technology and the data driven approach to examination efforts.   The Commission’s advances in technology and leveraging of big data collection to target...

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