is vital for registered investment advisers to review the proposed changes because the changes are important and should not be ignored. They will affect your business in the effort, cost and time
While changes are many, here are four key factors that Amendment :.
First, companies will be required to create and maintain a comprehensive “information security program.” What does this mean? The program would include written policies and procedures to protect customer records and data. The procedures would have to be detailed enough to cover administrative costs, technical and physical safeguards and should include how companies respond to unauthorized access.
Second, the scope of institutions covered by the Regulation SP will be broadened to include affiliates. Not only will the listed companies need a comprehensive information security program, and third party service providers will be required to maintain the same security. This means registered investment advisers will be required to secure outside help providers meet the changes subjective standards “comprehensive information security program.”
Third, companies must create policies and procedures that take data security violations. Data security violation include “sensitive personal information” is defined as “all personal, or combination of parts of personal information, which would allow unauthorized use, logging, or access to individual account or to establish a new account with individuals analyze information. “In the event of a violation, the business will need to create a written investigation into the incident, measures to control and prevent further unauthorized access, report violations to solicit customers and report violations and action taken regulators.
The next series of articles will take a close look at the proposed changes because they marked increase your company’s time, labor and cost of implementing this burden. While we all agree protecting customer data is of utmost importance, which change could have a significant impact on the business day to day activity and profitability.