Jennifer Gordon

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While there are many significant federal laws and regulations related to cybersecurity, states have led the way in regulating this area on a general, sector-agnostic basis, with the most notable and widely acknowledged state cybersecurity provisions being state data breach notification laws.  However, more recently, states have focused on passing comprehensive privacy, rather than security, laws, and 2025 promises to be a continuation of this trend, with eight additional comprehensive state privacy laws coming into effect next year.  Continue Reading Making a List and Checking it Twice:  Navigating State Privacy and Security Regulations This Year

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On October 26, 2022, in a divided 3-2 vote, the Securities and Exchange Commission (“SEC”) proposed a new rule, 206(4)-11, under the Investment Advisers Act of 1940 and related amendments (the “Proposed Rule”) requiring SEC-registered investment advisers to exercise effective and sufficient oversight over their service providers so as to fulfill the adviser’s fiduciary duty, comply with the federal securities laws and protect investors from potential harm.  Notably, the Proposed Rule prohibits advisers from outsourcing certain services or functions to service providers without meeting minimum diligence and monitoring requirements. Continue Reading The SEC’s Proposed Outsourcing Oversight Requirements for Investment Advisers