Monthly Archives: January 2015

Sometimes it is the little things that we don’t think about when looking at cybersecurity.  For example, require that all employees change the password on their computers at least every 90 days.  The password  should be a strong password and unique to that … Continue reading →

The SEC has sanctioned and fined and investment adviser because it failed to implement an adequate compliance program as required by Rule 206(4)-7.  One of the violations cited was using a template manual without tailoring it to the firm’s business. … Continue reading →

The SEC began allowing the use of electronic signatures in 2001.  It amended the books and records rule to permit electronic record keeping.  Beyond this, there hasn’t been much guidance from regulators regarding the use of e-signatures. If you decide … Continue reading →