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Trina L. Glass is a member of Stark & Stark’s Investment Management & Securities Group. Ms. Glass’ legal practice is devoted to supporting the regulatory and compliance requirements of financial institutions, specializing in securities filings, regulatory analysis, investigations, books and records requirements, regulatory inquiries and exams, risk mitigation, privacy, industry advocacy, advising on written supervisory and compliance policies, and other procedural matters related to broker-dealers, investment advisors, and investment companies.

On December 1, 2020, the New York Attorney General announced amendments to the New York Investment Advisory Act (the “Rules”) that will require investment adviser representatives (“IARs”) to register with the state of New York. If you render investment advice from a place of business in New York, now is the time to begin reviewing the rule and your registration obligations. This new law applies even if you previously filed a NY-IAQ on behalf of a state-registered investment adviser.

Continue Reading New York Investment Adviser Representatives Now Subject to Registration

The Securities and Exchange Commission’s (“SEC”) Supplement to Commission Guidance regarding Proxy Voting Responsibilities of Investment Advisers (“Guidance”) became effective on September 3, 2020. Additionally, the SEC final rules governing Proxy Advisors (“Amendments”), intended to improve the accuracy and transparency of information provided by proxy advisory firms, will go into effect on November 2, 2020 with a required compliance date of December 1, 2021, for certain provisions and full compliance by the 2022 proxy season. The Guidance and the Amendments are part of the SEC’s continued efforts to promote transparency, accountability and disclosure to investors during the proxy voting process.

Continue Reading Supplemental Guidance Regarding the Proxy Voting Responsibilities of Investment Advisers

As workplaces across the country look to adapt to the pressing need to slow the transmission of the COVID-19 outbreak, many employers are turning to remote work to keep their businesses afloat while reducing the possibility of transmission.

Many large tech employers such as Google and Amazon are already prepared for the needs of a remote workforce, but for others, the wide scale adoption of remote working comes with some real challenges. In the scramble to ensure the safety of others, it’s important that businesses don’t overlook the need to ensure cybersecurity as well.

Continue Reading Employee Remote Working: Cybersecurity Concerns

The presence of the Novel Coronavirus (“2019-nCoV” or more commonly known as “COVID-19”) is unprecedented in modern day times, as most of us have never experienced a global health threat. There are many unknowns with COVID-19 including, to what extent businesses are permitted to collect and share personal information and data in order to protect and preserve the public welfare. Currently, there are no overarching federal data privacy laws or protections to guide businesses on how to handle personal information and data during a pandemic. Specifically, how will your business balance collecting and sharing protected health information, employment data and location data in order to help control the rapid spread and ultimate containment of COVID-19.

Continue Reading COVID-19: Balancing Privacy Laws and Privacy Rights with Public Welfare