The North American Securities Administrators Association ("NASAA") proposed model investment adviser rules to address information security and privacy issues.
The proposal consists of three components:
- A requirement that an investment adviser maintain records relating to the proposed information security and privacy rule; and
- A provision that it would be an unethical practice for an investment adviser to "fail . . . to establish, maintain, and enforce a required policy or procedure." (Note that this provision is not limited to privacy procedures, but would pertain to any policy that the adviser is required to maintain.)
Comments on the proposal are due on or before November 26, 2018.
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