Category: Alerts

Alaric Compliance Alert: SEC Risk Alert Reg. S-P

On April 16, 2019 the Office of Compliance Inspections and Examinations (OCIE) of the Securities and Exchange Commission (SEC) released a Risk Alert1 that identifies a list of compliance issues related to Regulation S-P, the primary SEC rule regarding privacy notices and safeguard policies observed during recent OCIE examinations of registered investment advisers and broker-dealers. The Alert highlights OCIE’s continued focus on the proper adoption and implementation of policies and procedures for privacy notices and safeguards.

The May 3, 2019, pfm (private funds management) article, “Briefing: Are you in breach of Regulation S-P?” by Brian Bonilla, explores this topic through the discussion of the regulators’ findings and what private equity firms should do in order to reduce the risk of being cited for a privacy enforcement action under Regulation S-P.

Guy Talarico, CEO and Founder of Alaric Compliance Services, and Greg MacCordy, a Director at the firm, were quoted in this article regarding the compliance issues identified in the SEC Risk Alert and the impact on private equity firms.

  • Greg MacCordy, who most recently was at the SEC as an industry expert and specialized compliance examiner in the enforcement division stated that: “Every OCIE team that is going out, even if they didn’t participate in this set of risk exams, will be looking for this in a firm’s policies and procedures.”
  • Guy Talarico, “Now that the regulator has released this comprehensive risk alert there’s no excuse for private equity firms to not comply with Reg. S-P, at the very least firms should create a checklist based on this alert to improve their compliance rules.”

Is your firm prepared for an examination on compliance with Reg. S-P?

Alaric has created a check list in response to the Alert that can be downloaded for use by your firm.

ALARIC REG. S-P CHECKLIST

With over 275 years of cumulative financial services compliance expertise, we have managed over 100 regulatory examinations while serving as chief compliance officers. Leveraging this experience, our team of former regulators, lawyers, and in-house chief compliance officers can help your firm be audit-ready.

Call Alaric today to learn more about our compliance services at 1-888-243-2448 or info@alariccompliance.com.


1 https://www.sec.gov/ocie/announcement/ocie-risk-alert-regulation-s-p

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