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Don’t be a Turkey: Recipes for a Successful and (Hopefully) Cyberattack-Free Thanksgiving

Thanksgiving is a time to give thanks for the important things in life: family, friends, health and (hopefully) not being hacked in the past year.  Those firms and compliance officers who followed our Top 10 Cybersecurity Resolutions for 2015 are hopefully in good shape to continue warding off cyberattacks in the coming year. But for those who haven’t taken to heart our suggested...

The New York Department of Financial Services Releases Potential New Cybersecurity Rules

On November 9, Anthony Albanese, Acting Superintendent of the New York Department of Financial Services (NYDFS), sent a letter to the 18 members of the Financial and Banking Information Infrastructure Committee that outlines key regulatory proposals that NYDFS is considering as new regulations to increase financial sector cybersecurity defenses. The letter is written to “help spark...

The SEC’s Cybersecurity Enforcement Action: Rulemaking by Enforcement

The Securities and Exchange Commission recently brought an enforcement action against an investment adviser that, like a large number of companies, was the victim of a cyberattack. Although the SEC did not allege that any of the firm’s clients suffered harm, the Commission nonetheless sanctioned the firm for its allegedly unreasonable policies and procedures. In their article for...

SEC Charges Investment Adviser with Failure to Adopt Required Cybersecurity Policies Prior to Breach

On September 22, the Securities and Exchange Commission (SEC) announced that it had entered into a settlement order with R.T. Jones Capital Equities Management, Inc., a St. Louis-based SEC registered investment adviser, for failure to establish required cybersecurity policies and procedures in advance of a breach. As a result of the firm’s failure to adopt reasonable cybersecurity...

They’re Baaaack . . . SECs Office of Compliance Inspections and Examinations Releases New Cybersecurity Risk Alert

Yesterday, the U.S. Securities and Exchange Commission (SEC) Office of Compliance Inspections and Examinations (OCIE) released a Risk Alert describing OCIE’s 2015 cybersecurity exam initiative.  [link to www.sec.gov/ocie/announcement/ocie-2015-cybersecurity-examination-initiative.pdf].  As the Risk Alert notes, OCIE’s new cybersecurity initiative builds on information OCIE learned from...

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