What is the cybersecurity guidance?
The main document that outlines the SEC cybersecurity guidance (and the expectations from the OCIE) is the “OCIE’s 2015 Cybersecurity Examination Initiative.“
This five-page document spells out 34 specific cybersecurity measures that each firm needs to address.
Additionally, the SEC has published a number of other pieces of cybersecurity-related guidance that you should consider, including:
- The SEC OCIE has clearly stated that cybersecurity is a priority in 2019 (see the SEC OCIE 2019 Examination Priorities).
- In 2017, the OCIE published their observations after reviewing 75 firms’ cybersecurity practices (“Observations from Cybersecurity Examinations“).
- Also in 2017, they also published a risk alert focused specifically on ransomware (“Cybersecurity: Ransomware Alert“)
- In 2019, a new risk alert provided even more guidance about cybersecurity measures (see “Investment Adviser and Broker-Dealer Compliance Issues
Related to Regulation S-P – Privacy Notices and Safeguard Policies”).
Finally, there are also published guidelines around topics very closely related to cybersecurity, such as:
- Emails and texting: “Observations from Investment Adviser Examinations Relating to Electronic Messaging“
- Social media: “Investment Adviser Use of Social Media“
As with all regulatory matters, if you’re not sure which cybersecurity regulations apply to your RIA firm, consult with a qualified compliance attorney or compliance consultant.
Staying up to date on the latest SEC Cybersecurity Guidance
The best resources we’ve found to stay up to date on the latest cybersecurity guidance are:
1) Subscribe to the OCIE Announcements.
Head over to the Announcements page and enter your email address to get email notifications when a new piece of guidance is published.
2) Subscribe to updates from Lexology.
The Lexology website hosts fantastic articles written by attorneys on a wide variety of topics. Register for a free account, and they can send you daily or weekly email alerts.
We’ve found it’s best to sign up to get updates for the “IT & Data Protection” work area.
You’ll find the articles are helpful not only to read interpretation of the SEC’s guidance, but also to keep updated about other cybersecurity and privacy-related regulations that might impact your business.
Making sense of the Cybersecurity Guidance
Much of the decision-making process is left up to each individual registered investment advisor to decide what and how to address the guidance in their firm.
The devil is truly in the details — the guidance tells you WHAT to address, but not HOW to address it.
As part of our cybersecurity service for registered investment advisors, we’ve had an opportunity to see first-hand the areas where RIA’s tend to struggle.
As a result, we’ve published a number of topical guides that dive into the guidance and explore your options and make recommendations.
You can read these detailed guides here:
Banking Trojans are back, and they’re nasty. Click on the wrong email, and hackers drain your firm’s operating accounts. Incredibly, many of these attacks even defeat your bank’s two-factor authentication. Here’s a great article that explains how banking trojans bypass two-factor authentication. So what should every business do to protect yourself against banking trojans? The
Wire fraud is a huge problem for Registered Investment Advisors. Every day, criminals trick firms like yours into wiring funds out of client OR firm accounts. What is the SEC Cybersecurity Guidance on wire fraud? And what are the best practices to stop wire fraud in firms today? It’s critical that your staff identify these
As our work moves online and becomes more digital, our risks are changing. In recognition of this fact, registered investment advisors must take cybersecurity seriously. The SEC cybersecurity guidance lays out clear directions for taking cybersecurity risks seriously. And one of the biggest threats to your firm today is phishing. The SEC Cybersecurity Guidance seems
In our line of work, we hear a lot of myths and rumors. For example, some people say that Office365 isn’t SEC compliant because it’s in the cloud. We have also heard some people saying the same about Google’s G Suite. But what does the SEC Cybersecurity Guidance say? While the SEC Cybersecurity Guidance does
As businesses are digitally transformed, our exposure to risk is changing. In the financial industry, the stakes are much higher. The SEC Cybersecurity Guidance helps registered investment advisors respond to these threats. It also makes sure that they have a plan in place to respond to them. For example, one such threat is the loss
When firms think about cybersecurity, they’re tempted to focus on the tech. Hopefully, you’re already having internal conversations about which tools you need to fight phishing or to keep your mobile devices safe. One area where we’ve seen a lot of firms struggle, though, is in figuring out what to do when something BAD happens.
Protecting Your Business’ Most Sensitive Mobile Data Gone are the days of the rotary phone. Data is immensely portable. As we — individuals, consumers, corporate employees, investment advisors and financial investors — continue to rely on our mobile devices for everything, the level and amount of sensitive data that is stored on our mobile devices
Cybercriminals are quite nimble in outsmarting protection measures. This makes it essential to be proactive and stay one step ahead of bad actors. The SEC Cybersecurity Guidance provides a lot of information about security and compliance. But it doesn’t specify what steps firms should take to teach their clients how to be safe online from cyber threats.
Welcome back to SEC Cybersecurity Guidance: Business Continuity Planning. The first steps (found here in Part 1) are: List your Specific Needs, and Discuss and Document… and here, in Part 2, we talk, and plan, and test. Disclaimer: we are STILL not lawyers. We are cybersecurity practitioners who work with a lot of registered investment
If you’ve come to this site, you’re probably doing some research about SEC Cybersecurity Guidance. As part of the OCIE Cybersecurity Initiative, #6 in the SEC cybersecurity guidance clearly states that business continuity planning is a priority. Here’s what the SEC Cybersecurity Guidance says: “Please provide a copy of the Firm’s written business continuity of
Last week, we were sitting in a conference room with 20 people. These were smart people. All highly educated. They all use computers every single day. We were talking to them about ways to keep safe online. The conversation ranged from phishing to ransomware to staying safe at home. It was fun to be with
It’s a good idea… We have a lot of conversations with our clients about cybersecurity insurance. Adelia Risk doesn’t sell cybersecurity insurance. Instead, we provide a holistic cybersecurity service to small, high value, heavily regulated firms. As part of providing our service, cybersecurity insurance is a common topic. The single biggest misconception that we see?
Firing an employee, or having an employee leave voluntarily? Use this list of 28 measures to keep your business safe.
An average desk worker keeps 36 hours of work at his/her workspace at any one time