Regulatory entities require
registered broker-dealers, investment advisers, and investment companies to
establish written procedures and policies designed to:
- Ensure security and confidentiality of customer records and information
- Protect against anticipated threats or hazards to security and integrity of customer records
- Protect against un-authorized use or access to customer records & information that could result in substantial harm or inconvenience.
Failure
to govern cyber-security policies and procedures can result in fines and
suspension to firms and individuals. Governance failures include:
- Inadequate written policies and procedures
- Failing to enforce policies and procedures
- Failing to conduct periodic Assessments of Procedures and Measures
- Failing to respond to deficiencies identified through periodic assessments
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