On April 10, 2013, the U.S. Securities and Exchange Commission and the Commodity Futures Trading Commission approved joint final identity theft rules, codified as Regulation S-ID (“Identity Theft Red Flags”) by the SEC and as new subpart C (“Identity Theft Red Flags”) to Part 162 by the CFTC. Managers registered with the SEC or the CFTC must make determinations of coverage (and may have to implement responsive policies) by Nov. 20, 2013.
Click here to read more about whether you are covered, what obligations covered managers have and your next steps.