Regulation S-P, NPI, and Sub-Advisers: When “Sub-Advisers” Are Vendors – and When They Are Not
Executive Summary The Securities and Exchange Commission’s (SEC) 2024 amendments to Regulation S-P significantly reshaped advisers’ privacy and cybersecurity obligations, particularly in service-provider oversight and the timing of breach notifications … Continue reading Regulation S-P, NPI, and Sub-Advisers: When “Sub-Advisers” Are Vendors – and When They Are Not