Advisor Armor Advisor Armor

United States: SEC And FINRA Signal Renewed Focus On Vendor Management In Two Key Areas

The SEC and FINRA have made clear that market participants retain accountability for certain activities carried out on the platforms of external vendors and should not rely on vendors' controls to satisfy the firm's own obligations.  To avoid the pitfalls of such third-party arrangements, firms should incorporate these relationships into their regular risk assessments.  Where deficiencies are identified, firms should establish a system of risk management controls and supervisory procedures reasonably designed to manage the financial, regulatory, and other risks of this business activity.  Critically, Firms must implement and practice meaningful management oversight of vendor relationships, with clear escalation lines.

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Advisor Armor Advisor Armor

Happy Privacy Day!: Privacy & Cybersecurity Issues to Watch in 2020

2020 may very well be the most impactful year for data privacy and cybersecurity in the United States. In honor of Data Privacy Day, we discuss some of the reasons why that may be the case. In short, as privacy and cybersecurity risks continue to emerge for organizations large and small, the law is beginning to catch up which is prompting a significant uptick in compliance efforts.

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