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 [...]

By |September 5th, 2016|Categories: Cyber Security|0 Comments

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 [...]

By |August 9th, 2016|Categories: Cyber Security|0 Comments

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 [...]

By |July 12th, 2016|Categories: Cyber Security|0 Comments

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) [...]

By |June 13th, 2016|Categories: Cyber Security|0 Comments

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 [...]

By |May 24th, 2016|Categories: Cyber Security|0 Comments

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 [...]

By |May 18th, 2016|Categories: Cyber Security|0 Comments

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