Policies and Procedures (P&P)

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Blog | Regulatory Compliance

California AG Submits Final CCPA Rules for Approval  

June 12, 2020 by

On June 1, 2020, Xavier Becerra, the Attorney General for California, submitted the final package of regulations for the California Consumer Privacy Act (“CCPA”) to the California Office of Administrative Law (“OAL”). For businesses required to comply with the CCPA, the package outlines the requirements for privacy notices, methods for submitting requests to know and delete consumer information, verification of consumers, special rules regarding minors, and non-discrimination.

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Blog | Cryptocurrency & Digital Asset Counsel | Due Diligence Counsel

Another Technology Company Settles SEC Charges Over ICO Violations

February 12, 2020 by

Blockchain of Things (“BCOT”), a technology company, has agreed to settle charges with the Securities and Exchange Commission (“SEC”) for conducting an initial coin offering (ICO) without registering it as a securities offering or qualifying for any registration exemptions.  The settlement requires BCOT to agree to a cease and desist order, pay a $250,000 civil fine, return funds to any investors who file a request, and register the tokens as securities.

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A Costly Failure to Follow Written Policies and Procedures

January 8, 2020 by

On November 22, 2019, the Securities and Exchange Commission (“SEC”) ordered Channing Capital Management, LLC (“Channing”), a registered investment adviser located in Illinois, to pay a $50,000 civil penalty for failure to enforce its own written policies and procedures. This specific case underscores the importance of following the safeguards you put in place to protect all clients at all times.

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Blog | Regulatory Compliance

California Governor Signs CCPA Amendments, Privacy Related Bills into Law

December 18, 2019 by

California Governor Gavin Newsom has signed five bills that will directly amend the California Consumer Privacy Act (CCPA). Signed into law by then-Governor Jerry Brown on June 28, 2018, the CCPA was designed to notify consumers that they can learn about their personal data that is being collected and sold or distributed to third-parties or affiliates and be given the opportunity to opt-out. The effective date of the CCPA is January 1, 2020, and the enforcement date will be on July 1, 2020.

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PricewaterhouseCoopers LLP pays $7.9 to Settle SEC Improper Professional Conduct, Auditor Independence Charges

November 21, 2019 by

PricewaterhouseCoopers LLP has agreed to pay over $7.9 million to settle charges brought by The Securities and Exchange Commission (“SEC”). The SEC charges alleged that PwC, and its partner Brandon Sprankle, had engaged in improper professional conduct on 19 engagements on behalf of 15 audit SEC-registered issuers and violating auditor independence by performing non-audit services during an audit engagement.

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Annual Reviews & Risk Assessments | Blog

HCR Advisors Settles SEC Charges on Failure to Supervise and Implement Compliance-Related Policies and Procedures

November 15, 2019 by

HCR Wealth Advisors agreed to a cease-and-desist order, a $220,000 penalty, and a $328,912 payment to its harmed clients in order to settle charges with the U.S. Securities and Exchange Commission (“SEC”). The SEC complaint alleged that HCR had failed to reasonably supervise and implement its own compliance-related policies and procedures in response to fraudulent actions by one of its former investment advisors. 

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