Investment Management Industry Reminder: Investment advisers, brokerdealers and investment companies need to comply with a key provision of Regulation S-P by July 1, 2002
By Investment Management Practice Group
Under Regulation S-P, certain financial institutions, including investment advisers, broker-dealers and investment companies, have an affirmative and continuing obligation to maintain the confidentiality and protect the security of their consumers’ nonpublic personal information. Regulation S-P limits the circumstances and purposes under which this nonpublic personal information can be disclosed by a financial institution to nonaffiliated third parties. By July 1, 2002, these financial institutions must ensure that their contracts with nonaffiliated third parties prohibit those third parties from disclosing or using the nonpublic personal information they receive under the contract other than to carry out the purposes for which the information was disclosed and in a manner that complies with Regulation S-P.