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SEC OCIE’s Cybersecurity Initiative: What Your Firm Needs to Know

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There has been a recent flurry of news reports, analysis and webinars in the securities law world around the Securities and Exchange Commission's ("SEC's") Office of Compliance Inspections and Examinations ("OCIE") proposed 2014 Cybersecurity Initiative. Launched as a major news item this month after the SEC's OCIE published its April 15, 2014 Risk Alert devoted to the topic, the Cybersecurity Initiative redirects the financial industry's compliance focus back to SEC examinations, as OCIE purports to conduct exams on "more than 50 registered broker-dealers and registered investment advisers", focusing specifically on a firm's "cybersecurity preparedness." So what do you need to know the most from this latest Risk Alert? The areas that OCIE will be most concentrating on include:
  • The entity's cybersecurity governance [through risk assessments, an inventory of technology, and internal policies and procedures ("P&P")];
  • Identification and assessment of cybersecurity risks [malware, network breaches, etc.];
  • Protection of networks and information [encryption, etc.];
  • Risks associated with remote customer access and funds transfer requests [including external controls for authentication of identity];
  • Risks associated with vendors and other third parties [tracking new software packages, etc.];
  • Detection of unauthorized activity [how to track the notifications process for intrusions, etc.]; and
  • Experiences with certain cybersecurity threats.
Also key to this Risk Alert is its 7-page Appendix, which details a "sample list of requests for information" that the SEC may request in conducting an examination of your firm. While this list is not fully inclusive of all the requests that could be made, it is highly recommended to use it as an important guide for assuring your firm is on track with SEC examination standards. Consider assessing this Appendix and its contents with your compliance and executive team, and then develop and implement an effective cybersecurity policy within your organization. Not only will you be safeguarding and protecting your clients, but you will be better prepared for your next regulatory exam. For further information on this and other related subjects, please contact us at [email protected] or (619) 298-2880.

About the author

Jacko Law Group provides tailored legal services and effective strategies for success, delivering exemplary solutions to complex legal and regulatory challenges to ensure that both business efforts and compliance obligations are satisfied.

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Dharmi is an excellent securities lawyer who understands the law as it pertains to these cases. She is extremely proactive and represents her clients well. I highly recommend Jacko and Dharmi.
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I’ve had the privilege of working closely with this firm in my role as Chief Compliance Officer and I can confidently say they are an exceptional compliance partner. Their depth of experience is immediately evidentand they bring a level of practical knowledge. What I truly enjoy is their ability to translate complex regulatory requirements into plain English, often using real, everyday examples that make implementation far more manageable. They are also incredibly responsive and reliable. In a field where timing matters, their prompt communication and thoughtful guidance have been invaluable. If you’re looking for a compliance attorney who combines expertise, clarity, and professionalism, I highly recommend them.
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Curt Rocca
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Michelle and the team at Jacko Law Group have helped guide through a variety of critical circumstances as we ventured through the uncharted and unfamiliar territory of becoming and successfully operating as an RIA. I have particularly appreciated Michelle's personal involvement and genuine caring about us and our organization. She has been responsive and her counsel has been consistently on-point and helpful. She artfully guided us through our initial filing process and first SEC exam process - which went very well. Very grateful to Michelle and her team.
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Michelle and her team were excellent to work with, front to back. They helped me to understand the challenges ahead and were always proactive in their consultation through every step of my transition. JLG truly know the wealth management industry very well and did a great job of understanding the challenges unique to my business. Without them, I can confidently say I would not have felt as comfortable through the transition as I did. Fortunately, that's not something that stops there - Michelle and her team have kept in touch to ensure that I'm on top of certain administrative issues, trends, and simply showing me that they care about my business and success. I look forward to continuing to work with them for many years to come.
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Dharmi Mehta was extremely helpful when my business partner and I transitioned to a new RIA firm. She and her staff were all very professional. Her guidance during our transition was invaluable. I highly recommend Dharmi and Jacko Law Group.
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Dharmi and Amandeep were a delight to work with. They assisted me with a claim and stuck with me the entire way through. Dharmi's advice was invaluable, and I was most impressed by her clear and professional communication. From beginning-to-end, both Dharmi and Amandeep kept me well informed. Their entire team are proud of their work and rightfully so. Thank you!
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My mentor once told me that a good attorney is worth their weight in gold — and that couldn't be more true of Michelle and Amanda. Their expertise, professionalism, and responsiveness were top notch every step of the way. It's rare to find legal partners who are not only sharp and thorough, but also genuinely invested in your success. I’m grateful for their guidance and highly recommend them to anyone seeking trusted legal counsel.
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everistus etafo
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It is my great Privilege to share my Review of what Atty Dharmi Mehta of Jacko Law Group did for me and by extension for my family. From the first time complimentary conversation we had having spoken to several other Lawyers ,l knew she was the right person for the Job .Because of her background as a former RR ,she was professional,kind, Empathetic,listened and was focused on fighting for me. From a potential of been terminated with cause ,l was able to walk away with a clean U5 with a validation that l did nothing wrong except what was in the best Interest of my clients. I hope nobody ever has to go through what l have Experienced, but if you do ,you want Dharmi Mehta beside you .Rest assured your service Deserve 10 stars but this forum only allows 5. Me and my family are forever grateful and will make sure that any RR who needs an advocate will know about you . Everistus Etafo
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Karen Althaus
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I have worked with Jacko Law Group for 2 different business situations that necessitated an attorney. In both cases, the team was very thorough & competent. Their attention to our situation and the extra effort they put into our case(s) was very much appreciated. I would highly recommend Jacko Law Group!