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 [...]

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 [...]

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 [...]

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) [...]

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 [...]

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 [...]