Benson R. Cohen

Aug 10, 2023 | lexology.com | W. Hardy Callcott |Jay G. Baris |James Brigagliano |Benson R. Cohen |Ranah Esmaili |Nathan J. Greene | +3 more

On July 26, 2023, the U.S. Securities and Exchange Commission (SEC or Commission) proposed new rules for broker-dealers (Proposed Rule 15(1)-2) and investment advisers (Proposed Rule 211(h)(2)-4) on the use of predictive data analytics (PDA) and PDA-like technologies in any interactions with investors.1 However, as discussed below, the scope of a “covered technology” subject to the rules is much broader than what most observers would consider to constitute predictive data analytics.

Aug 8, 2023 | lexology.com | W. Hardy Callcott |Jay G. Baris |James Brigagliano |Benson R. Cohen |Ranah Esmaili |Nathan J. Greene | +2 more

On July 26, 2023, the U.S. Securities and Exchange Commission (SEC or Commission) proposed new rules for broker-dealers (Proposed Rule 15(1)-2) and investment advisers (Proposed Rule 211(h)(2)-4) on the use of predictive data analytics (PDA) and PDA-like technologies in any interactions with investors.1 However, as discussed below, the scope of a “covered technology” subject to the rules is much broader than what most observers would consider to constitute predictive data analytics.