The Texas Lawbook has published an article by Toby Galloway and Justin Freeman, “SEC Enforces Identify Theft Red Flags Rule for the First Time: What it Means for Texas Businesses.”  The article examines the Securities and Exchange Commission’s (SEC) recently settled case involving a dually registered broker-dealer and investment adviser for violations of cybersecurity

Financial services firms occasionally implement programs for their representatives to receive incentives in connection with specific product or service offerings. For as long as firms have used such programs, securities regulators have scrutinized them. The latest iteration of regulatory attention to sale incentives, however, signals a shift in strategy that carries broader implications for financial