The SEC requires registered investment advisers to adopt and implement written cybersecurity policies and procedures. Under Regulation S-P, firms must have safeguards for customer records and information, including written incident response programs and customer notification procedures. The SEC's examination staff evaluates firms on governance and risk management, access controls, data loss prevention, vendor oversight, training, and incident response capabilities. Our cybersecurity programs are designed to address every element that SEC examination staff assess.

Regulation S-P requires broker-dealers, investment companies, and registered investment advisers to adopt written policies and procedures addressing administrative, technical, and physical safeguards to protect customer records and information. The amended rule now requires firms to develop incident response programs that include procedures for investigating and responding to unauthorized access or use of customer information, and for providing timely notification to affected customers. We build Reg S-P compliant programs that include all required elements and produce the documentation that demonstrates compliance during examinations.

Financial advisory firms face several industry-specific cybersecurity risks: spear-phishing campaigns impersonating clients requesting money movements or account changes, unauthorized data exfiltration by departing advisors who take client books of business, account takeover attacks targeting custodial accounts and portfolio management platforms, insider threats involving unauthorized access to material nonpublic information, and ransomware attacks that lock advisors out of critical systems during market hours. Each risk requires targeted defensive measures that generic IT security programs simply do not address.

While SOC 2 reports are not universally mandated for all financial services firms, they are increasingly requested by institutional clients, fund administrators, custodians, and business partners as evidence that your firm has implemented adequate security controls. For fintech companies integrating with financial institutions, a SOC 2 Type II report is often a prerequisite for partnership. Even if not required, a SOC 2 report demonstrates a level of security commitment that differentiates your firm in competitive situations. We guide firms through the entire SOC 2 readiness and certification process.

We implement a combination of technical controls and procedural safeguards. Data loss prevention tools monitor for large-scale data downloads, email forwarding of client lists, and USB device usage. User behavior analytics detect anomalous access patterns that may indicate a departing advisor copying files. Our offboarding security procedures ensure that access is revoked immediately and comprehensively. We also create forensic audit trails that document exactly what data was accessed and when, providing evidence for regulatory proceedings or litigation involving misappropriated client information.

The NAIC Insurance Data Security Model Law is the primary framework, and it has been adopted by a growing number of states. The law requires licensed insurers and producers to develop written information security programs, conduct regular risk assessments, implement controls proportional to risk, establish incident response plans, investigate cybersecurity events, and notify the state insurance commissioner of material incidents within 72 hours. Individual states may have additional requirements beyond the model law. We track the regulatory landscape across all states where your firm operates and build compliance programs that satisfy each jurisdiction's specific requirements.

Yes, this is a service we provide frequently for financial services firms. Institutional investors, fund administrators, custodians, and prime brokers often require detailed cybersecurity due diligence questionnaires before establishing or maintaining business relationships. These questionnaires can be extensive, covering hundreds of questions about your security controls, policies, incident history, and governance. We help you complete these questionnaires accurately and efficiently by drawing on the comprehensive documentation our security program generates. When your cybersecurity program is well-documented and robust, due diligence questionnaires become a competitive advantage rather than a burden.

The cost depends on your firm's size, regulatory obligations, complexity of your technology environment, and the scope of services you need. We offer scalable engagement models that serve independent advisors with a handful of employees as effectively as we serve mid-sized institutions. The more relevant question is the cost of not having a proper cybersecurity program: SEC enforcement actions can carry penalties of millions of dollars, FINRA fines can be substantial, cyber insurance claims may be denied without documented controls, and the client attrition from a publicized breach can devastate assets under management. Call 919-348-4912 for a customized assessment and quote.

We can begin our compliance and risk mapping within days of engagement. For most financial services firms, we deliver a complete baseline assessment within 30 days, written policies and a security architecture design by day 60, and full control deployment by day 90. If your firm is facing an imminent SEC or FINRA examination, we offer accelerated timelines to address the highest-priority compliance gaps first. Our 23+ years of experience and pre-built financial services security frameworks allow us to move quickly without sacrificing quality.