Alt Data and the SEC

An interview with Igor Rozenblit

Alternative data or alt data is now fueling investment decisions at the world’s leading private investment funds, but what is alt data and when does its use trigger a violation of U.S. securities laws? Igor Rozenblit, the long time co-head of the private funds unit of the U.S. Securities and Exchange Commission (SEC) explains.

Alt data can include internet scrapings, satellite data, mobile data, credit card transactions, and much more.  In what can be massive data sets, how do companies parse out material nonpublic information (NMPI) that may trigger securities law obligations? Rozenblit shares examples including the infamous case involving the app data seller, App Annie. He goes on to share how alt data users (those who are trading on the data) can violate policy and due diligence obligations by simply relying on data provided by data sellers. Rozenblit also weighs in on whether internet data scraping can trigger NMPI and deceptive practices concerns. 

Igor Rozenblit is a securities law and investment professional. He served as the co-head of the private funds unit of the SEC from 2010 to 2021.

  • Attorney CLE accreditation 


SEC Charges App Annie and its Founder with Securities Fraud – Press Release, U.S. Securities and Exchange Commission


Relevant Law

Section 10(b) of the Exchange Act makes it unlawful:

To use or employ, in connection with the purchase or sale of any security registered on a national securities exchange or any security not so registered, or any securities-based swap agreement [1] any manipulative or deceptive device or contrivance in contravention of such rules and regulations as the Commission may prescribe as necessary or appropriate in the public interest or for the protection of investors.

Securities Exchange Act of 1934

Section 17(a) of the Securities Act

Use of interstate commerce for purpose of fraud or deceit

It shall be unlawful for any person in the offer or sale of any securities (including security-based swaps) or any security-based swap agreement (as defined in section 78c(a)(78) of this title) by the use of any means or instruments of transportation or communication in interstate commerce or by use of the mails, directly or indirectly—

(1) to employ any device, scheme, or artifice to defraud, or

(2) to obtain money or property by means of any untrue statement of a material fact or any omission to state a material fact necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading; or

(3) to engage in any transaction, practice, or course of business which operates or would operate as a fraud or deceit upon the purchaser.

Securities Act of 1933


Related Explainers

When is alt data illegal? an explainer video with Igor Rozenblit