Yesterday, two of my colleagues here at Ulmer, Fran Goins and Michael Hoenig, published an article in @BLaw Insight in response to a recent report by FINRA outlining the best practices for BDs to deal with cyber threats. Since this is undoubtedly a subject of considerable interest to many of you, I wanted to share
Cybersecurity
Tips For Staying Off The SEC’s Naughty List In 2019
I recently had to the opportunity to sit in on a talk from high ranking CFTC and SEC enforcement officials at a local bar association meeting. The purpose of the get together was, in part, to let industry folks and their lawyers know what the regulators will be focusing on in the near future in…
FINRA’S 2018 Exam Priorities Reflect Business As Usual
I would imagine that the point of FINRA releasing its list of exam priorities each year is to help firms who are actually going to be examined, by providing a glimpse into FINRA’s playbook so they can address, proactively, the issues they know FINRA will focus on. To be forewarned is to be forearmed, right? …
The Equifax Breach May Be A Problem For More Than Just Equifax
All of you who use Equifax to conduct a part of your CIP responsibilities, raise your hands. Ok, now, only to those of you whose hands are in the air: how many of you have checked your firm’s incident response plan to determine the steps that need to be taken in the event of a…
Ransomware In 2017: Not A Pretty Picture
I am happy to share this post from my colleague, Greg Stein, about ransomware. While ransomware is not something unique to the financial services industry, because, as criminal Willie Sutton famously answered when asked why he robbed banks, our industry is “where the money is,” BDs, IAs and banks do seem to attract more than…
WannaCry Virus Triggers SEC Security Alert To BDs And Investment Management Firms
Readers of this blog know that sales practice issues represent my sweet-spot. Today, in what is probably a welcome departure from my rants, my partner (and co-chair of Ulmer’s Financial Services & Securities Litigation Group) Fran Goins, who knows all things about data privacy and cybersecurity, offers some helpful advice on dealing with the WannaCry…