On January 27, 2020, the U.S. Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (“OCIE”) published its Cybersecurity and Resiliency Observations. Cybersecurity and data protection for market participants have been key focuses of OCIE for several years. These observations provide useful insights into OCIE’s examination priorities in these areas. OCIE compiled these observations by observing industry practices during examinations of investment advisers, broker/dealers and other registrants. The report notes that there is “no such thing as a ‘one-size fits all’ approach” to cybersecurity preparedness, but that the observations might factor into “their consideration of how to enhance cybersecurity preparedness and operational resiliency.” The report details seven specific areas of focus.
