Category: Cybersecurity

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SEC Offers More Guidance on Cybersecurity Best Practices and Pitfalls – Part 2 of 2

This post continues our discussion of the Risk Alert released on August 7, 2017, by the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) regarding conclusions drawn from its yearlong review of the cybersecurity practices of 75 asset management firms and funds.  The sweep, deemed OCIE’s Cybersecurity 2 Initiative, covered broker-dealer, investment adviser, and investment … Continue Reading

SEC Offers More Guidance on Cybersecurity Best Practices and Pitfalls – Part 1 of 2

On August 7, 2017, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) released a Risk Alert summarizing its conclusions from a year-long review of the cybersecurity practices of a 75 firms — including broker-dealers, investment advisers and investment companies.  The sweep, OCIE’s Cybersecurity 2 Initiative, ran from September 2015 to June 2016 and covered … Continue Reading

Investment Advisers Act Compliance Developments in 2015

The year 2015 is shaping up to have an unusual focus on the center of that string of relationships tracing the path from end-investor to asset class — that is, the nuts and bolts of asset management “operations.”  Click here to read my recent article about key operations-oriented compliance developments for investment advisers in 2015.… Continue Reading

Transfer and Sub-Transfer Agent Cybersecurity: Implementing SEC Guidance

The cybersecurity threats faced by mutual fund transfer agents (TAs) and sub-transfer agents (Sub-TAs) are unique because their information technology (IT) networks house a massive amount of personally identifiable information (PII) belonging to the funds they serve (Fund PII).*  In its recent IM Guidance Update on Cybersecurity, the SEC staff stressed boards’ responsibility to oversee … Continue Reading
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