SEC Fires the Second Round on Cyber Exams
The Future of The SEC Exam is Here. How to Respond to the New Request. Last week the SEC Office of Compliance Inspections and Examinations (“OCIE”) released its second Cybersecurity Examination Initiative; the first shot was fired in April, 2014 and was more commonly referred to as the “Cybersecurity Sweep Document [...]
Boards and C-Suites in Shareholders’ Legal Crosshairs for Data Breaches
Boards and C-Suites in Shareholders' Legal Crosshairs for Data Breaches As companies attempt to balance data security and privacy with data utility, security breaches have exploded in frequency. Hardly a month passes without headlines of a business experiencing a data breach involving the unauthorized disclosure of consumers’ personal and financial information. [...]
Logical Encryption For Your Firm
Logical Encryption Controls to Secure Your Firm Encryption is all the rage today. Regulators are asking firms about their encryption policies, and those who do not have well-executed strategies can find themselves at risk of examination deficiencies or enforcement. With NSA spying allegations, the general public has begun to understand that [...]
Why Investment Advisers Should Care About FINRA
SEC Risk-Based Exam Navigation Utilize FINRA’s RCA Survey for SEC Examination Prep Many Investment Advisers pay little attention to the Financial Industry Regulatory Authority’s guidance and news items. This is a mistake, not only because FINRA has been out in front on issues such as Business Continuity, Identity Theft, AML, and [...]
3 Principles of Governance
Three Simple Principles of Governance in Financial Services The word governance comes from the Greek word kubernan, which means “to steer a ship.” This definition applies to what governance is: a methodology of successfully steering a company through waters that are oftentimes rough. Successful seafaring relies on 3 simple principles: Any activity that [...]
What to Expect from the SEC as Cybersecurity Hits the Docket
What to Expect from the SEC as Cybersecurity Hits the Docket The New York Times reported on Sunday that the Securities and Exchange Commission has enforcement with cybersecurity implications on the schedule. The authors speculated about something that we have all known for years, the SEC is going for high-profile or [...]