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BIS and IOSCO consult on cyber resilience

BIS’ CPMI and IOSCO are consulting on principles for cyber resilience for FMIs. The guidance includes: - stressing the importance of board and senior management attention to a successful cyber resilience strategy...more

Privacy Tip #11

Whenever you open a new bank account, credit card or debit card account or other account such as a health savings account, the bank or credit card company is required to send you a notice of your privacy practices under the...more

Why are Companies and their Directors and Officers Still Behind on Cyber Security Oversight and Disclosure?

Over the past three years, I’ve been outspoken about the need for better board oversight of cyber security, as well as the need for better cyber security disclosure. The severity of the cyber threat is so significant to...more

Return of the Cyborg Part II: First-Ever SEC Cybersecurity Enforcement Action Filed Against Investment Advisory Firm

As our last newsletter highlighted, the government is ramping up enforcement investigations against both regulated entities and public companies for perceived cybersecurity failures. Proving the point, on September 22, 2015,...more

Starwood Hotels hit with payment card malware attack

Last Friday (November 20, 2015), Starwood Hotels announced that it was hit with a payment card malware attack affecting 50 of its North American hotels. The president of Starwood Hotels Americas stated in a letter to...more

Following a Regulatory Trend, CFTC Inches towards Cybersecurity Testing Requirement

Commodity Futures Trading Commission (CFTC) Chairman Timothy Massad has recently stated that the CFTC may soon issue principles based standards that would require certain CFTC-regulated entities to conduct penetration,...more

Financial Regulatory Developments Focus - November 2015 #4

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

Upping the Ante: Cybersecurity, the SEC and the Perils of Being Unprepared

The U.S. Securities and Exchange Commission is finally getting serious about cybersecurity – and for good reason. If the ever-growing business and headline risks aren’t enough to scare investment advisers and broker-dealers...more

NY DFS Proposes New Cybersecurity Regulations for Financial Institutions

The New York Department of Financial Services (NYDFS) has distributed a letter to various federal and state regulatory agencies and associations proposing the development of new cybersecurity regulations for financial...more

UK and US carry out cyber-testing exercise

The UK and US Governments have carried out a joint exercise with leading global financial firms to enhance cooperation...more

New Bank Examination Procedures for Cybersecurity

There is no more pressing problem facing business organizations today, of all types, than cybersecurity threats. For a highly regulated industry like banking, regulators are watching closely to see how the IT governance...more

NYDFS Letter: “Potential” Cybersecurity Regulations for Insurers

On November 9, 2015, the New York Department of Financial Services (NYDFS) issued a letter that describes what insurers can expect from the Department’s ongoing assessment of cybersecurity measures. The letter parallels...more

NFA Adopts Cybersecurity Guidance for NFA Members

On October 23, 2015, the National Futures Association (NFA) adopted its Interpretive Notice Regarding Information Systems Security Programs (the Notice). As noted in our prior Password Protected update, the Notice requires...more

SEC Proposes Rules To Enhance Transparency And Oversight Of Alternative Trading Systems

The SEC announced this week its proposal to substantially overhaul the rules regarding alternative trading systems (“ATS”), often referred to as dark pools. The proposed rules would require firms operating ATSs to make...more

Recognizing the Role and Importance of the CISO

In July of this year, we reported on the Cybersecurity Assessment Tool published by the Federal Financial Institutions Examination Council. The FFIEC is an interagency organization that establishes the examination standards...more

Expect New Cybersecurity Regs from New York DFS

DFS identified several areas that would be the subject of specific requirements in the potential regulations. These include requirements for (i) cyber security policies and procedures, (ii) third-party service provider...more

FFIEC Releases Revised Management Booklet with Emphasis on Sound IT Governance

On November 10, the FFIEC issued a revised Management booklet, which outlines the principles of overall sound governance and, more specifically, IT governance. The booklet is one of 11 that makes up the FFIEC’s Information...more

NY DFS Signals a Detailed Framework for Cybersecurity Compliance

On November 9, 2015, the New York State Department of Financial Services (“DFS”) sent a letter to a number of state and federal financial regulators signaling that DFS may issue comprehensive cybersecurity regulations for...more

Financial Services Weekly News - November 2015 #3

Regulatory Developments - MSRB Publishes Compliance Advisory for Municipal Advisors: On Nov. 12 the Municipal Securities Rulemaking Board (MSRB) published its first municipal advisor compliance advisory, developed...more

DOJ Unseals Indictment Against Individuals for Alleged Involvement in Hacks Against Various U.S. Institutions

On November 10, the DOJ unsealed an indictment against three individuals, Gery Shalon, Joshua Samuel Aaron and Ziv Orenstein, for allegedly orchestrating and committing computer hacking crimes against U.S. financial...more

Tougher Scrutiny on Cybersecurity at Banks in 2016

Cybersecurity has been a focus as part of bank exams for years. Now the Federal Deposit Insurance Corp. (FDIC) is increasing its scrutiny of banks’ cybersecurity practices to ensure that the issue is getting appropriate...more

NIST issues draft IT Asset Management special publication

The National Cybersecurity Center of Excellence (NCCoE) has issued its draft practice guide entitled “IT Asset Management” designed for the financial sector. The comment period for the guide is open through January 8,...more

New York Considers Cybersecurity Regulations for Financial Institutions

On Monday, November 9, 2015, the New York Department of Financial Services (NYDFS) sent a letter to federal and state regulators announcing that it is considering new cybersecurity regulations for financial institutions. ...more

Cybersecurity and Data Privacy: Potential New Cybersecurity Regulations for Financial Institutions and Insurance Companies (11/15)

On the heels of recent high profile cyber-attacks against financial institutions and insurance companies, the New York State Department of Financial Services released a letter on November 9, 2015 that outlines proposed...more

Home Office publishes draft Investigatory Powers Bill

The Home Office has published a draft of the Investigatory Powers Bill, including provisions giving FCA powers to acquire communications data. Communications data is described as being the context but not the content of a...more

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