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Cybersecurity: SEC Is Starting to Scrutinize Registrants’ Practices

By Daniel Nathan & Libby Greismann on April 22, 2014
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The SEC plans to examine the cybersecurity practices of over 50 registered broker-dealers and investment advisers. The SEC announced its plan in an April 15, 2014 Risk Alert, which closely follows the March 26 Cybersecurity Roundtable at which Chair Mary Jo White underscored the importance of cybersecurity to market security and customer data protection. At the Roundtable, Chair White emphasized the “compelling need for stronger partnerships between the government and private sector” to address cyber threats.

The Risk Alert included a comprehensive Appendix detailing the types of questions the SEC may be asking registrants in these exams, on such topics as cybersecurity governance, risks associated with remote customer access and risks associated with vendors and third parties. The sample questions include whether companies have discovered malware in their systems, suffered a network breach or found that computers used by customers and vendors to remotely access networks have been compromised since January 2013.

To read the full alert, click here.

Daniel Nathan

Mr. Nathan is a partner in the firm’s Securities Litigation, Enforcement and White-Collar Defense Group. Mr. Nathan’s practice includes representation of companies and individuals who are involved as witnesses or subjects in investigations conducted by the SEC, the CFTC, FINRA and other regulatory…

Mr. Nathan is a partner in the firm’s Securities Litigation, Enforcement and White-Collar Defense Group. Mr. Nathan’s practice includes representation of companies and individuals who are involved as witnesses or subjects in investigations conducted by the SEC, the CFTC, FINRA and other regulatory entities involving financial institutions or transactions. Mr. Nathan also consults with financial institutions on examinations, supervisory procedures, product disclosure and supervision, and other regulatory matters.

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  • Posted in:
    Privacy and Cybersecurity
  • Blog:
    IM Insights
  • Organization:
    Morrison & Foerster LLP

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