NASAA Annual Report; Top Five Cybersecurity-related Issues

April 29th | 2020

The North American Securities Administrators Association ("NASAA") recently published its Annual Report on state-registered investment advisers’ regulatory compliance. Much like the SEC’s Examination Priorities letter, the NASAA’s report highlights cybersecurity. In fact, the NASAA included a top five cybersecurity-related deficiency list:

  • no testing of cybersecurity vulnerability

  • lack of procedures regarding securing or limiting access to devices

  • lack of procedures related to internet connectivity

  • weak or infrequently changed passwords

  • no or inadequate cybersecurity insurance

Helpfully, The NASAA has a guide and a Cybersecurity Checklist for Investment Advisers that includes 89 assessment areas to help state-registered investment advisers identify, protect, and detect cybersecurity vulnerabilities; and to respond to and recover from cyber events.

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