- What information is collected from clients;
- What sources that information is collected from (over and above information provided by the client);
- The firm’s basis for sharing this information;
- What safeguards you have in place to protect client information; and
- Any state-specific privacy regulations the firm is subject to.
Why You Should CareIdentify theft, cyber fraud and high profile security breaches have become common occurrences. The media attention they receive has undoubtably heightened your clients' sensitivity to protecting their personal information.
As a general policy, supervised persons should not release confidential client information without first consulting with the CCO. This mitigates your regulatory risk by ensuring that nonpublic information is disclosed only to the extent it is needed to conduct business for that client.
Our RecommendationsTo ensure that your firm is keeping up with regulatory requirements and industry best practices in this area:
AdvisorAssist’s CCO Series: Top 12 Regulatory Deficiencies for RIAs is a series of articles that will help your firm understand and avoid the most common compliance deficiencies found by regulators. Our goal is to help you increase your confidence that your firm remains “exam ready.” Click here to read more posts from our CCO Series: Top 12 Regulatory Deficiencies for RIAs. We would welcome the chance to learn more about you and your firm. Click here to request an introductory call from one of our consultants.