About Lyman Terni

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So far Lyman Terni has created 56 blog entries.

Regulatory Rollback and Cybersecurity

Should Current Political Winds Impact Your Approach? A tremor ripped through the Investment Adviser and Broker-Dealer space last week as President Trump signed an Executive Memorandum, a call to investigate of the “Fiduciary Rule” and a likely precursor to specific attempts to roll back Dodd–Frank “Wall Street Reform and Consumer Protection Act”. [...]

By |2018-01-17T10:41:49-05:00February 7th, 2017|Cyber Security|Comments Off on Regulatory Rollback and Cybersecurity

2017 Exam Priorities – The SEC & The Cyberlandscape

Examination Priorities - Making Your Program Real The Priorities: More of The Same The SEC launched its 2017 Exam priorities last week. For the last couple of years, when the long-awaited priorities have been released, I have been reminded of a press conference that the late Presidential candidate and Senator, Fred Thompson [...]

By |2018-01-17T10:42:11-05:00January 17th, 2017|Cyber Security|Comments Off on 2017 Exam Priorities – The SEC & The Cyberlandscape

Inventories Revisited

Inventories Revisited - Making Your Asset Lists Work for You Inventory_Web.jpgIT Security in the Investment Adviser space faces an interesting quandary: does security drive compliance, or does compliance drive security? From the security side, the continuous call is that compliance with regulations should come as a result of good security. In essence, [...]

By |2018-01-17T14:13:24-05:00September 27th, 2016|Cyber Security|Comments Off on Inventories Revisited

Form ADV Amendments & Internet Presence

In the final, sleepy week of Summer on the 25th of August, the SEC adopted rule changes and additions to Form ADV which were proposed in May of 2015. The justification for the scope creep of information and “big data” is to fill gaps in intelligence, modernize, and enhance information provided to both [...]

By |2018-01-17T14:17:18-05:00September 5th, 2016|Cyber Security|Comments Off on Form ADV Amendments & Internet Presence

Zero Days for Investment Advisers

The Direct Impact of Stuxnet on the SEC and Investment Advisers Now that Alex Gibney’s remarkable documentary about the proliferation of the Stuxnet malware is available on Amazon, a wider audience and modest infosec professionals can enjoy the slow motion train wreck that has all investment advisers discussing cybersecurity. If you are [...]

By |2018-01-17T14:43:41-05:00August 9th, 2016|Cyber Security|Comments Off on Zero Days for Investment Advisers

The Formal Business Continuity and Transition Plan

On June 28th, the SEC announced that it is building upon its body of rules and expectations driven by concerns over cybersecurity and technology failures. The proposed Rule will require firms to “adopt and implement written business continuity and transition plans that include certain specific components, and to maintain relevant records of [...]

By |2018-01-17T14:48:16-05:00July 12th, 2016|Cyber Security|Comments Off on The Formal Business Continuity and Transition Plan

DLP Revisited Through The Lens of Enforcement

What You Should Know About MSSB's Enforcement Last year’s RT Jones enforcement was a shot across the bow to Investment Advisers of all sizes that the SEC was paying attention to cybersecurity and was taking it seriously. Fast forward to June 8, 2016 and to Morgan Stanley Smith Barney’s (MSSB) cybersecurity [...]

By |2018-01-17T14:54:13-05:00June 13th, 2016|Cyber Security|Comments Off on DLP Revisited Through The Lens of Enforcement

Windows 10, Vendor Due Diligence, and Reg S-P

Windows 10 Upgrade Due Diligence for Investment Advisers and Broker Dealers Why are we talking about upgrading workstations and laptops in a blog that, to date, has focused pretty heavily on IT Issues and Regulatory Compliance? It’s not that we’re changing our focus. It’s that you, as a CCO need to [...]

By |2018-01-17T14:58:09-05:00May 24th, 2016|Cyber Security|Comments Off on Windows 10, Vendor Due Diligence, and Reg S-P

Immutable Security Laws For The CCO

Immutable Security Laws For The CCO - #7 - The Well-Administered Network I recently had the chance to hear David Glockner, Director of the Chicago Regional Office, speak on IT Security and have a few words with him on the subject. The Chicago Office, of course, led the effort on the R.T. [...]

By |2018-01-17T15:30:18-05:00May 18th, 2016|Cyber Security|Comments Off on Immutable Security Laws For The CCO

The CCO and the Keys to the Kingdom

As investment advisers and broker-dealers consider sophisticated and costly monitoring tools as a panacea for IT Security, we still find a regular need for fundamental information practices, which could have a much greater impact on preventing and controlling breach. The good news for businesses, whether you consider the firm to be small [...]

By |2018-01-17T15:11:58-05:00May 2nd, 2016|Cyber Security|Comments Off on The CCO and the Keys to the Kingdom
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