SEC Risk Alert Highlights Policy Design and Implementation Failures and Roadmaps Future Enforcement

The SEC recently issued a risk alert highlighting some of the most frequent issues it has identified regarding compliance with Regulation S‑P. “The biggest challenge is to build internal support within a firm for day-in/day-out basics like compliant privacy notices, data mapping, improved training and better control over personal devices. That stuff may not be the sexiest, but the SEC clearly wants more focus on everyday blocking and tackling and is prepared to sanction firms that neglect it,” Debevoise & Plimpton partner Jeremy Feigelson told the Cybersecurity Law Report. See also “SEC Officials and the Defense Bar Talk Cybersecurity Enforcement Trends and Takeaways From Recent Cases” (Nov. 28, 2018).

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