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Regulatory Expectations for Cybersecurity Practices at Broker-Dealers  (Volume 54, Number 1–January 13, 2021)

Author:  Daniel Nathan.; Heather Sussman.; Colleen Hespeler.

Source: Volume 54, Number 01, January 1 2021 , pp.1-11(11)

Review of Securities & Commodities Regulation


As the number of data breaches has grown rapidly in recent years, cybersecurity has become an increasingly important priority for broker-dealer regulators. The authors address this subject in detail, focusing on SEC and FINRA rules, regulations, and extensive guidance. They then turn to the lessons to be drawn from the law and guidance and conclude with a discussion of SEC and FINRA enforcement actions arising from cybersecurity failures and the lessons to drawn from those cases.

Keywords: Regulations S-P and S-ID; FINRA Supervisory and Reporting Rules; Enforcement Actions

Affiliations:  1: Orrick, Herrington & Sutcliffe LLP; 2: Orrick; 3: Orrick.

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