The New Jersey Bureau of Securities announced its 2026 annual investment adviser examination, with a particular focus on firms' use of artificial intelligence and cybersecurity protocols. The examination requires nearly 800 registered investment adviser firms to answer questions about AI use in portfolio management, data protection policies, and third-party vendor due diligence. Failure to comply may result in administrative action.
Firms must complete the electronic examination by June 30, 2026, providing detailed responses about AI use, cybersecurity policies, employee training, and third-party vendor due diligence. Non-compliance may lead to administrative action.
In-house legal teams should review vendor agreements with third-party service providers, particularly those handling client data or providing AI tools. Key clauses to examine include data protection and cybersecurity requirements, vendor due diligence obligations, and provisions for periodic security audits. Additionally, customer agreements should be reviewed for disclosures about AI use in investment recommendations and data handling practices. Employee contracts and training policies should also be updated to reflect new cybersecurity and AI compliance requirements.
Entity
New Jersey Bureau of Securities
Industry
Financial ServicesOfficial Press Release
https://www.njoag.gov/new-jersey-bureau-of-securities-annual-examination-of-investment-advisers-will-look-closely-at-ai-and-cybersecurity/
Investment Adviser Written Examination.aspx
https://www.njconsumeraffairs.gov/bos/Pages/Investment-Adviser-Written-Examination.aspx
New Jersey Attorney General Enforcement Page
https://www.njoag.gov/about/divisions-and-offices/division-of-consumer-affairs/
"New Jersey Bureau of Securities"
"N.J.A.C. 13:47A-14.16"
"the examination takes a close look at the use of Artificial Intelligence (AI) in the construction of investment portfolios or recommendations to clients"
"The examination also focuses on online data protection, seeking to determine whether firms have written policies and procedures on cybersecurity"
"Each registered investment adviser is required to complete the examination in the electronic format provided no later than June 30, 2026"
$650K
The New Jersey Attorney General and Division of Consumer Affairs announced that Match Group, Inc. will pay $650,000 and change its business practices to settle allegations that it misrepresented or failed to disclose its criminal background screening policies and practices to New Jersey users, violating the New Jersey Consumer Fraud Act and the Internet Dating Safety Act. Under a Consent Order, Match must accurately represent its screening policies, notify existing New Jersey members of updated disclosures within 150 days, and post clear and conspicuous disclosures and safety notifications about the limitations of criminal background screenings.
On August 31, 2026, New Jersey Attorney General Jennifer Davenport and the Division of Consumer Affairs joined the FTC and a bipartisan coalition of 21 other states in suing Amazon, alleging that for over seven years the company secretly rigged its advertising auctions—converting advertised 'second price' auctions into first-price auctions with hidden 'soft reserve price' surcharges—overcharging more than 500,000 small- and medium-sized businesses and extracting tens of billions of dollars. The complaint alleges Amazon actively concealed the surcharges, gave false and misleading answers to advertisers who asked directly about the auction format, and applied inflated upcharges on high-volume shopping days like Prime Day and Black Friday. The lawsuit was just filed; no penalties or remedies have been imposed yet.
A bipartisan coalition of state attorneys general led by New Jersey, California, Colorado, and Kentucky is taking Meta Platforms, Inc. to trial, alleging that Meta designed addictive features on Instagram and Facebook that harm minors' mental health, illegally collected data from children under 13 without the required protections under COPPA, and misled users about platform safety. Opening arguments begin August 18, 2026, in the U.S. District Court for the Northern District of California. No monetary penalty or final remedy has yet been imposed.
A coalition of 21 state attorneys general and Pennsylvania filed lawsuits against the Trump Administration, DOT, FMCSA, DHS, and AAMVA to prevent the unlawful demand for a database containing personal information of 17 million commercial driver's license holders. The lawsuits allege violations of federal privacy laws and the Administrative Procedure Act, and seek an emergency order to block the data transfer.
Attorney General Jennifer Davenport joined a coalition of 17 attorneys general in sending comment letters to the Office of the Comptroller of the Currency and the Federal Reserve Board, urging them to deny OppFi's application to acquire BNC National Bank and obtain a national bank charter. The coalition argues that the charter would allow OppFi to circumvent state usury laws and offer high-cost loans with APRs up to 200%, harming consumers.
$400.0M
Attorney General Jennifer Davenport joined a coalition of 43 states and territories in announcing a $400 million settlement in principle with Sandoz Inc. to resolve allegations of widespread price-fixing and anticompetitive conduct in the generic drug market. Sandoz will pay approximately $469 million total including prior settlements, and has agreed to internal reforms to ensure fair competition.