Eversheds Sutherland Cybersecurity and Privacy Insights Blog
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Sutherland and the Financial Services Institute Complete Benchmarking Survey on Cybersecurity Practices

WASHINGTON—Sutherland Asbill & Brennan LLP and the Financial Services Institute (FSI) have completed a survey of FSI members concerning cybersecurity issues. The survey included responses from 39 broker-dealers (92% of which were dually registered as investment advisers), ranging in size from fewer than 100 registered representatives to more than 2,000. The survey covered a variety...

What Funds Can Take Away From SEC Cybersecurity Guidance

In late April 2015, the U.S. Securities and Exchange Commission responded to the heightened risk of data breaches at the entities it regulates by issuing prescriptive guidance on cybersecurity for all investment advisers and registered investment companies, including mutual funds, insurance separate accounts and business development companies (funds). In her article for Law360,...

SEC Updates Guidance on Cybersecurity

Emphasizing the critical importance of cybersecurity to registered investment companies (RICs), including insurance separate accounts and business development companies, and to investment advisers, the SEC’s Division of Investment Management issued new Cybersecurity Guidance on April 28, 2015. As RICs and advisers become ever more dependent on information technology to conduct their...

SEC Releases Results of 2014 Cybersecurity Exam Sweep

On February 3, the Securities and Exchange Commission (SEC) issued a Risk Alert prepared by its Office of Compliance Inspections and Examinations (OCIE) that summarizes the results of a sweep of more than 100 broker-dealers and investment advisers that OCIE undertook in 2014 in order to assess the level of cybersecurity preparedness of the examined firms. A list of questions that OCIE...

SEC and FINRA Exam Priorities

In their recent examination priorities letters, both the SEC and FINRA highlighted cybersecurity as an area of focus for 2015 exams. In the SEC letter, the Office of Compliance Inspections and Examinations (OCIE) explained that it will continue its 2014 initiative to examine broker-dealers’ and investment advisers’ cybersecurity compliance and controls, and also plans to expand the...

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