Simpson Thacher Attorneys Author Dow Jones Risk Journal Article on New SEC Data Privacy Requirements
Partners David Blass and Meaghan Kelly, and Associates Jeffrey Caretsky and Raymond Jensen authored an article titled, “Is Your Firm Ready for New SEC Data Privacy Requirements?,” which was published in Dow Jones Risk Journal. The article describes how, with a deadline for the SEC requirement to update data privacy policies and procedures looming on December 3, 2025, in-scope entities (registered investment advisers, investment companies, broker dealers, transfer agents) should focus on enhancing their data privacy policies and procedures. It further details the amendments, which require firms to adopt an incident response program, including breach notification, policies to ensure oversight of their service providers and how to prepare for examinations related to updated data privacy procedures after the December compliance date.
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