Application of the Gramm-Leach-Bliley Act to Colorado Registered Investment Advisors
A common question for state registered investment advisors is regarding their responsibilities for maintaining the privacy of their hedge fund investors. Many state securities divisions provide notice on their website regarding the applicability of the Gramm-Leach-Bliley Act to the manager’s investment advisory activities. The Colorado Securities Division, which has a savvy and knowledgeable staff, has provided Colorado investment advisers with an overview of their responsibilities with regard to “non-public personal information.” In general most hedge funds do not have a need to disclose the “non-public personal information” of their investors to outside parties, but if a hedge fund manager does need to disclose such information to third parties, then the manager should discuss this in greater detail with his hedge fund attorney.