The Securities and Exchange Commission (SEC) recently released a report that examined 75 finance firms registered with the SEC, including broker-dealers, investment advisers and investment companies (“funds”). The report assessed overall industry practices as well as legal and compliance issues associated with cybersecurity preparedness.
While several of the findings were positive, clearly there is still much to be done. Fortunately, the report showed that cybersecurity is being taken seriously. No longer are firms insisting they’re too small to worry about cyberattacks. The threat is out there and companies are aware they need to protect against them.
Cybersecurity preparedness is an ongoing commitment that requires firms to:
- Continually assess and re-evaluate the policies they have in place, as well as what cyberthreats are “trending.”
- Keep track of all the compliance regulations that affect their industry and how those are continuing to evolve.
- Hire the right people and train their employees in cybersecurity best practices.
- Constantly test their own network and act on vulnerabilities.
And these steps are just the beginning! That is why, when a firm wants to assess their cybersecurity practices, I usually recommend starting by answering 6 key questions. Let’s break these questions down, using the SEC report as a reference.
1. Who is responsible for cybersecurity within your firm?
The report found that all broker-dealers and a large majority of advisers and funds maintained cybersecurity organizational charts and/or identified and described cybersecurity roles and responsibilities for the firms’ workforce. This is a great start.
2. How well do you vet your vendors?
Almost all firms either conducted vendor risk assessments or required that vendors provide the firms with risk management and performance reports (i.e., internal and/or external audit reports) and security reviews or certification reports.
Additionally, while vendor risk assessments are typically conducted at the outset of a relationship, over half of the firms also required updating such risk assessments at least annually. Many firms also required third-party vendors to periodically provide logs of their activity on the firms’ networks.
This marks a major improvement compared with how vendor assessments were previously conducted. Firms are recognizing the risk that vendors can pose to their network and are taking action to prevent it.
3. What is your incident response plan?
Nearly all the firms had plans in place for addressing access incidents. In addition, most had plans for denial of service incidents and unauthorized intrusions.
However, while the vast majority of broker-dealers maintained plans for data breach incidents and most firms had plans for notifying customers of material events, less than two-thirds of the advisers and funds appeared to maintain such plans.
Plan maintenance is where firms prove their commitment cybersecurity preparedness and determine a cyberattack will not wipe them out. By having a plan in place, firms have already done most of the work. If your current plan is not being maintained, you should consider it a priority.
4. How do you educate your firm’s employees?
While the report found that many of the firms required all employees to complete cybersecurity awareness training, there were no substantial policies in place to ensure training occurred nor were there protocols surrounding employees who did not complete the required training.
Cybersecurity training for employees should be mandatory—not just as part of new-employee orientation, but as an ongoing practice. It’s important that training is offered in a way that is engaging and memorable so your employees will retain the information. And of course, policies must be in place to ensure employees take this training seriously. We offer some ideas about Security Awareness training here.
5. What are your vulnerability assessment and penetration testing methodologies?
Most of the firms examined conducted penetration tests and vulnerability scans on systems they considered critical. Unfortunately, it appeared that a number of firms did not actually fully remediate some of the high-risk observations discovered from these tests.
This lack of remediation efforts is problematic. Vulnerabilities should be addressed immediately to reduce the risk to your network. Learn more about vulnerability assessments and penetration tests.
6. How are you meeting your industry’s regulations and compliance obligations?
For the most part, the firms had policies and procedures in place to meet SEC regulatory requirements. However, some firms were not adequately conducting system maintenance, such as the installation of software patches to address security vulnerabilities and other operational safeguards to protect customer records and information. Part of the problem is the use of outdated operating systems that were no longer supported by security patches.
This is a significant oversight. It was negligence like this that led to the spread of ransomware such as WannaCry earlier this year. After a cyberattack of that scale, it is clear that patches must be completed as they come available, not as a reactive measure.
Furthermore, there are the impending requirements of GDPR. Any firms that do business with Europe (in any capacity) will be affected by these new regulations. It is important that firms are aware of what will be required of them and are actively taking measures to prepare themselves for additional compliance obligations.
The firms mentioned in this report have taken critical steps in protecting their network and preparing for a cyberattack. But the job is never done. All organizations – regardless of their industry – need to be constantly evolving their cybersecurity practices to stay current. It is the firms that fall behind that are most susceptible to attack.
eSentire offers security experts to help you assess risks, develop cybersecurity roadmaps to address known gaps and build a comprehensive program that meets the requirements of your industry. If you would like to learn more about our services, please visit our ADVISORY SERVICES.