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SEC Publishes Cybersecurity Risk Alert

On August 7 2017, the U.S. Securities and Exchange Commission (SEC), through its Office of Compliance Inspections and Examinations (OCIE), published a Risk Alert summarizing observations on how broker dealers, investment advisers, and investment companies have addressed cybersecurity issues. The OCIE examined 75 financial firms registered with the SEC. The examinations focused on the firms’ written policies regarding cybersecurity. The OCIE observed increased cybersecurity preparedness since a similar 2014 observational initiative was conducted but also noticed areas of compliance and oversight that could be improved.

In particular, the OCIE observed that almost all firms that were examined maintain cyber-security related written procedures regarding protection of customer and shareholder records and information. Additionally, the examinations confirmed many of the firms are conducting cybersecurity risk assessments, penetration tests and vulnerability scans, and maintaining clearly defined cybersecurity organizational charts for workforces. However, the OCIE also observed that, in some cases, firms are administering vague or unclear cybersecurity policies, are not adequately following cybersecurity policies, or are not conducting adequate system maintenance to address system vulnerabilities. The Risk Alert concluded that, despite some improvements, cybersecurity remains one of the top compliance risks for financial firms. The OCIE noted that it will continue to monitor financial firms’ compliance in this area.