Daniel A. Nathan

Daniel A. Nathan

Morrison & Foerster LLP

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Latest Posts › Cybersecurity


NY Department of Financial Services: Check Your Vendors’ Cybersecurity

According to a recent report released by the New York Department of Financial Services (NYDFS), the financial industry has a long way to go in overseeing the cybersecurity capabilities of outside vendors who carry out...more

4/24/2015 - Banking Sector Cybersecurity Financial Institutions NYDFS Third-Party Risk

Investment Management Legal + Regulatory Update - February 2015

In This Issue: - SEC Proposes Rule Requiring Hedging Disclosure - SEC Reports the Result of its Cybersecurity Sweep of Broker-Dealers and Investment Advisers - House Passes Bill to Ease Volcker Rule and Other...more

2/27/2015 - Background Checks Broker-Dealer CFTC Compliance Cybersecurity Data Protection Dodd-Frank Enforcement Enforcement Actions Equity Swaps FINRA Hedging Investment Adviser Investment Management OCIE SEC

FINRA Issues its Cybersecurity Report, Providing Tools and Encouragement to Broker-Dealers

FINRA recently issued a Report on Cybersecurity Practices (“Report”), growing out of its targeted examination of firms last year. To issue the Report, FINRA gave careful consideration to the needs of many broker-dealers for...more

2/25/2015 - Broker-Dealer Brokers Corporate Governance Cyber Attacks Cybersecurity Data Breach Data Protection Financial Adviser Financial Institutions FINRA Risk Assessment

SEC Reports the Result of its Cybersecurity Sweep of Broker-Dealers and Investment Advisers

An SEC cybersecurity sweep examination by the SEC’s Office of Compliance Inspections and Examinations (OCIE) found that 88 percent of the broker-dealers (BDs) and 74 percent of the registered investment advisers (RIAs) they...more

2/13/2015 - Broker-Dealer Cyber Attacks Cybersecurity Data Protection Investment Adviser OCIE SEC

Investment Management Legal + Regulatory Update -- June 2014

In This Issue: - Regulation ..SEC Begins to Scrutinize Registrants’ Cybersecurity Practices ..SEC Staff Sets Boundaries for Adviser Testimonials in Social Media ..Chair White: SEC to Tackle High-Frequency...more

6/16/2014 - Broker-Dealer Cybersecurity Dark Pool FINRA High Frequency Trading Investment Adviser JOBS Act Legislative Agendas Marijuana New Legislation Private Equity Funds SEC SEC Commissioner SIFIs Transaction Fees

Cybersecurity: SEC Is Starting to Scrutinize Registrants’ Practices

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...more

4/23/2014 - Cybersecurity Data Protection Investigations SEC

FINRA Announces a Sweep to Assess BDs’ Cybersecurity

After announcing that cybersecurity will be one of its 2014 examination priorities, FINRA wasted no time before commencing a sweep. FINRA announced a Targeted Examination Letter to conduct an assessment of firms’ approaches...more

2/10/2014 - Cybersecurity Data Breach Data Protection FINRA

SEC Examiners to Take a Close Look at Firms’ Cyber Security

A high-level SEC official told an industry group yesterday that the National Examination Program (NEP) will be reviewing asset managers’ policies and procedures for preventing cyber attacks. In particular, the SEC is looking...more

2/3/2014 - Compliance Cyber Attacks Cybersecurity Data Protection NEP SEC

Broker-Dealer Cybersecurity: Protect Yourself or Pay the Price

In its recently issued 2014 Regulatory and Examination Priorities Letter, FINRA stated that cybersecurity remains a priority given the ongoing cybersecurity issues reported across the financial services industry, including...more

1/13/2014 - Broker-Dealer Critical Infrastructure Sectors Cybersecurity Data Protection FINRA Regulation S-P

SEC and CFTC Issue Identity Theft Rules

Today, April 19, 2013, the Securities and Exchange Commission (“SEC”) and the Commodity Futures Trading Commission (“CFTC”) published in the Federal Register rules and guidelines requiring their respective regulated financial...more

4/22/2013 - CFTC Cybersecurity Data Protection Dodd-Frank FCRA Identity Theft SEC

FINRA Provides Early Guidance About Its Exam Priorities; Firms Should Take Notice

In its annual summary of regulatory and examination priorities, the Financial Industry Regulatory Authority (FINRA) signaled that it will aggressively pursue market misconduct. The January 11, 2013 report follows closely on...more

1/16/2013 - Broker-Dealer Compliance Cybersecurity FINRA Investment Adviser Investors

Financial Services Report -- Winter 2012

In This Issue: Bureau Report; Operations Report; Beltway Report; Arbitration Report; Mortgage Report; Privacy Report; Preemption Report; and Plastics Report. Excerpt from the Bureau Report: World’s Most...more

12/18/2012 - American Express CFPB Chase Bank Cybersecurity Debt Collection Dodd-Frank FDIC FTC Google Mobile Apps MySpace Project Catalyst Stress Tests Truth in Lending Act (TILA)

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