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You hear more reports of firms turning to e-mail encryption, perhaps spurred on by that new Massachusetts regulation or simply as a means of offering clients greater protections against identify theft.Turn that concept around now and consider when clients send your firm encrypted e-mails. One of you ...
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Many firms lump their policy disclosures to clients when they offer their annual Form ADV, Part II. Be careful. Some firms forget to include a disclosure or two. This is particularly true with privacy disclosures, says Krista Zipfel, CEO/president of Advisor Solutions Group in Newport Beach, Calif.A ...
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These pages have carried news of the Bay State's new data security rules so it came as a big surprise when a CD arrived in the mail from the Massachusetts Securities Division responding to an IA Watch request for a list of state-registered RIAs, which instead revealed confidential U4 data on more th ...
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Click here to open a Word file that is an example of an N1–A form. A peer has its subadvisers complete this form so it can better track the portfolio managers and their conflicts. It also asks for compensation and owned securities, too.
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The SEC has joined with seven other federal agencies to offer a Web site you can use to construct the appropriate privacy notice for your clients. This is the latest iteration of regulators' efforts to provide you with model forms to satisfy the safe harbor under federal law (IA Watch, Nov. 23, 2009 ...
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Data security glows as hot as a Mojave Desert mirage in July (IA Watch, March 1, 2010), so here are more pointers to get it right. Don't forget to shut the tap off to terminated employees so they can't gain access to sensitive client information after they leave.Program your logon system to shut out ...
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You have responsibilities to avoid a breach of confidential client data thanks to the SEC's Reg S-P (IA Watch, Nov. 23, 2009), even as attention turns to Massachusetts and its new data security rules, which go into effect March 1 (IA Watch, Feb. 22, 2009).The most difficult part of either Reg S-P or ...
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The nation's toughest data security regulation goes into force in days, and it will have ramifications far beyond the borders of Massachusetts. "This is just a prelude of things to come," predicts Terrence Davis, an attorney with Schiff Hardin in Washington of the 4-page Massachusetts regulation. Mo ...
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Many advisory firms maintain compliance logs that track breaches as well as resolutions. You have choices in the format in which you keep these records - and freedom whether to even preserve them in the first place.Some suggest that a best practice would be to keep such logs in a WORM format - write ...
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This story seems especially timely given the recent federal indictment charging three alleged hackers with stealing 130 million credit card numbers. More and more investment advisory firms use the Internet to send sensitive client data - and there are a lot more than just three hackers out there.Man ...
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