What Am I Looking At? Making Sense of Your Cyber Testing Reports

It’s no surprise that Compliance and IT do not speak the same language. Compliance staff often speak in terms of regulations and policies, whereas bits and bytes are the language of IT staff. This distinction is clear when it comes to cybersecurity risk management, as the compliance and IT audiences are looking for different takeaways … Continued

Race to the Top – States Push to Broaden Breach Reporting Requirements

Facebook just reported a massive data breach impacting over 50 million user accounts. And while most investment advisers are not likely to experience a breach of that scale, what is likely is that a cyber incident will occur at some point. Consequently, state regulators continue to expand the protections they require for their residents through … Continued

Data Breach Prevention and Response

According to the Investment Firm of the Future, a report published by CFA Institute earlier this year, 24% of the organization’s members rated cybersecurity as their firm’s top technology priority. With the myriad challenges facing investment professionals in 2018, that’s a striking number. What to do? E.J. Yerzak, Director of Cyber IT Services for Ascendant Compliance … Continued

California Privacy Law Brings GDPR-Lite to the U.S.

New Act Will Give Consumers Rights to Access and Delete Their Data In what has become an ongoing race among states to have the toughest privacy regulation in the U.S., California has jumped to the front. On June 28, 2018, California’s legislature unanimously passed a privacy bill that was later signed by Governor Jerry Brown, … Continued

Paradigm Shift in SEC Exams, Benefits of a Mock Exam

For investment advisers currently going through an SEC exam, the process likely bears little resemblance to exams of old. Call it the new normal, a paradigm shift, or simply the effects of the SEC having to do more with less, but anecdotal evidence among those now experiencing the exam process suggests some interesting new trends. … Continued

Publicly Available Information Heightens Need for Cybersecurity Vigilance

For any business, “ports” that allow for communication generally need to be open (for example, ports 80 and 443 for websites, and port 500 for VPN access). While most of these ports allow you to engage in critical functions, there are often ports that remain open despite being unneeded or unused. These available ports present … Continued

SEC Discloses Cybersecurity Breach That May Have Led to Insider Trading

The determination of hackers to exploit existing cybersecurity vulnerabilities of government agencies and businesses shot to the forefront again last Wednesday, when SEC Chair Jay Clayton revealed that the commission’s EDGAR database had been hacked in 2016 through a software vulnerability in the test filing component of the system. According to Clayton, the breach was … Continued

SEC Cyber Sweep Highlights Areas In Need of Improvement

The results of the SEC’s second cybersecurity sweep examinations are in, and they paint a picture of an industry that has come to grips with the need to address cybersecurity risk, but where the canvas is incomplete in many respects.

Colorado Joins New York in Mandating Cybersecurity Controls for Financial Institutions

On the heels of the recently adopted New York State Department of Financial Services Cybersecurity Regulation (23 NYCRR 500), Colorado has followed suit with its own set of protections. The Colorado Division of Securities has issued cybersecurity regulations applicable to broker dealers and investment advisers registered with the state, which are codified in Sections 51-4.8 … Continued

Latest Content

Takeaways and Tips Related to SEC Risk Alert on Regulation S-P

On April 16, 2019, the SEC released a Risk Alert providing a list of compliance issues related to Regulation S-P, the primary SEC rule regarding privacy notices and safeguard policies of investment advisers and broker-dealers. As with other risk alerts, these were deficiencies noted by OCIE in regulatory examinations. Though the deficiencies were fairly common … Continued

How to Be a Wildly Effective Compliance Officer

Being a Compliance Officer is no easy task. Administering a compliance program, implementing controls to help protect clients and the firm, and staying on top of new regulations is only part of the job. Compliance Officers are also expected to be flexible and pro-business. So how do you do it all? How can you be … Continued

Mitigating the Risk of Insider Trading

One of the biggest risks affecting investment advisers is the potential that material non-public information (“MNPI”) may be misused, leading to a charge of insider trading. Advisers should implement controls to mitigate these risks. Steven Stone of Morgan, Lewis & Bockius, LLP, Salvatore Cincinelli of the FBI and David Chaves of Tone at the Top … Continued

Compliance 2.0 – Being a Strategic Partner in Your Firm

Compliance as a profession continues to evolve. With Enron, Bernie Madoff and numerous other failures paving the way for rulemaking across industries and nations, the days of drawing a short straw, getting drafted into a compliance role and operating in isolation outside of the business are – or should be – ancient history. Since the … Continued

Big Data Part III: Preparing for the Future of Global Regulatory Governance

United States and European Union reporting requirements imposed on investment managers have exploded since the Global Financial Crisis and, with the imminent arrival of SFTR in Europe, it seems poised to expand again. The challenge of reporting trades, transactions and contracts in multiple jurisdictions requires firms to embrace technology as regulators continue to look to … Continued

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Ascendant works together with clients to identify and assess critical needs through customized plans. If you need assistance with compliance functions, regulatory services, cybersecurity or technology tools, we’d love to speak with you.