The Human Element of Cybersecurity
Beginning in 2014, both the Securities Exchange Commission (“SEC”) and FINRA began to examine the heightened risk financial services firms face regarding unauthorized access to the electronic data that these firms routinely maintain as part of their businesses. As part … Read More
‘Tis the Season: The Human Aspect of Project Management
“I don’t measure a man’s success by how high he climbs but how high he bounces back when he hits the bottom.” ~General George Patton As another year is quickly coming to a close, so often organizations reflect on metrics … Read More
Helpful Tips for New Chief Compliance Officers
A Different Perspective On November 30, 2015, SEC Commissioner Luis Aguilar published “Commissioner Aguilar’s (Hopefully) Helpful Tips for New SEC Commissioners.” What follows is an application of a portion of Commissioner Aguilar’s advice geared for a new Chief Compliance Officer … Read More
2015 Core Compliance End-Of-Year Checklist Update
On November 18, 2015, SEC Chair Mary Jo White gave testimony to the Committee on Financial Services, outlining the various steps the SEC has been taking and what they plan on doing going forward in regards to the financial markets … Read More
Project Management Lessons – Time and Money Aren’t Enough
All compliance officers are de facto project managers. Whether you are conducting an internal audit, authoring and implementing policies and procedures, rolling out new compliance technology, or training employees on compliance requirements – all these projects go towards helping your … Read More
SEC Chair White to Recommend Required Third-Party Compliance Reviews
In her testimony yesterday before the Committee on Financial Services of the United States House of Representatives SEC Chair Mary Jo White shared the following regarding third-party compliance reviews: At my direction, the staff is also preparing a recommendation to … Read More
Adviser Sanctioned by SEC for Sub-Adviser False Performance
On November 16, 2015, the Securities and Exchange Commission (“SEC”) issued administrative and cease and desist proceedings against Virtus Investment Advisers, Inc. (“Virtus”) for marketing a “materially inflated, and hypothetical and back-tested, performance track record” of one of its sub-advisers, … Read More
Cybersecurity: Importance of Using a Minimum Two-Factor Authentication
Unauthorized Access Cybersecurity is essentially a regime to prevent unauthorized access. Authorized users are authenticated most commonly via a username and password. However, requiring just a password with a username for access is considered a weak protection control. Weak because … Read More
