Commissioner Luis A. Aguilar delivered the morning keynote address last Thursday at the SINET Innovation Summit 2015 in New York. We continue to pay close attention when the Commissioner speaks as he has been a proponent on the subject of Cybersecurity, has contributed key guidance in previous speeches, and was the driving [...]
Recent guidance from the Financial Services Information Sharing and Analysis Center (FS-ISAC) and the FBI suggests that Business Email Compromise (BEC) that leads to fraudulent wire transactions remains a significant threat to the industry. While the controls listed in the June 19th Fraud Alert were primarily directed at executives, Advisors and other [...]
The Division of Investment Management’s recent cybersecurity guidance suggested that firms consider implementing training to provide guidance to officers and employees “concerning applicable threats and measures to prevent, detect, and respond to… threats and that monitor compliance with cybersecurity policies and procedures.” In addition, the Division suggested that firms “may wish to [...]
This may be one of those cases where regulatory expectation is just as important as the written Rule. The Division of Investment Management's April 28 guidance used the following language: “In the staff’s view, there are a number of measures that funds and advisers may wish to consider in addressing cybersecurity risk.” [...]
The regulatory expectation from both the SEC and the DOJ is that your firm will implement some form of a data classification system that will allow you to adequately protect your business’s sensitive information. We have previously discussed the creation and implementation of such a program. In this post we will take [...]