In Part Three of our Risk Outlook Webinar Series, Michael Corcione, Managing Director of Cordium, spoke about compliance and cybersecurity trends in the investment industry. Although cybersecurity risks and struggles can vary from firm to firm, it is important to address a number of key areas.
Continue reading for quick takeaways or scroll down to watch the 30 minute video replay.
Good security can be achieved as firms move from reactive to proactive strategies. Firms usually start with the goal of checking the box for regulators, but they need to get beyond the 'check-the-box' exercises and test controls. The SEC’s 2015 cybersecurity guidance update provided more specific insights on cybersecurity focus areas for investment firms - governance and risk assessments, training and awareness, incident response, data loss prevention, access rights controls, and vendor risk management. Hedge funds and investment firms should use this as a framework, understand how they have addressed these areas and where they need to improve.
A good cybersecurity program starts with the leadership team, and they need to set the tone from the top down. This way everybody understands the impact of risk and its effects on the firm. Leaders should acknowledge risk, understand risk, and lead ongoing discussions firm-wide.
During Part 2 of our Risk Outlook Webinar Series we spoke with Eze Castle Integration Director Dan Long about how investment firms should address evolving cybersecurity risks, third party service provider oversight and employee training and education. Many of the points Dan addressed highlight questions hedge funds and private equity firms should be asking themselves.
Read on or scroll to the bottom to watch the full, 30-minute replay.
What is our commitment to cybersecurity and what is our outlook on the future?
Regulators and investors continue to ask more questions about cybersecurity because they want to know that firms are effectively mitigating risk. To meet these growing expectations, firms must demonstrate that you take cybersecurity risk seriously and have implemented sound systems, policies and procedures to combat those risks. As the threat landscape and technology continue to evolve, investment management firms need to evolve accordingly and develop better ways to counteract threats. Firms don’t necessarily need to implement every available security technology, but they should be keenly aware of their options and have a plan to effectively mitigate as much risk as possible.
How are we addressing third party risk and oversight?
Investment management firms often rely on third party vendors to obtain functionality or capabilities that they need, want or can’t afford to produce on their own. But moving functions out of the firm's control can present challenges. With any outsourced function, the firm inherently takes on additional risks at the hands of the third party. But it's critical for investment managers to limit those risks through sufficient due diligence. To combat vendor risk, financial firms need to maintain strict oversight of all third party relationships and investigate security practices and protocols, particularly for those vendors who have access to the firm's confidential information. An outsourced vendor should be providing the same level of security (or better!) as your firm would if the function was under in-house control.
Private equity firms have been slow to embrace outsourcing, but managing data and technology is more complex than ever. With increasing regulatory requirements and a growing urge to focus on core competencies, PE firms are shifting their views of the back office. In case you missed our recent webinar on 'The Transformation of Private Equity Operations', speakers from Citco Fund Services and Eze Castle Integration examined the changing tide for private equity operations and how CFOs, CTOs and fund managers alike can control operating costs, maximize efficiency and better perfect operational workflows.
Drivers for change.
The number one reason for managers to make the switch to an outsourced solution is the desire for managers to get back to their roots. The idea of back office transformation is really founded in that managers have found themselves spending much more time doing everything but raising money and investing money.
Beneath this layer, back office transformation is also driven by regulation, investor transparency, the lifecycle of a private equity firm, and global reach. Slow adoption, fast results. The private equity sector has been slow on the uptake when it comes to outsourcing, and we contribute this lag due to lack of education on the process and benefits of outsourcing. In the past three to five years, adoption in the PE space has increased because it is cost effective, secure and feature rich. Private equity firms that have made the switch wonder why others are not doing the same. The idea of leveraging an experienced managed service provider is one that private equity firms have really embraced because there is no burden for firms to hire and attract talent, which can be challenging and expensive.
As we work with clients on completing due diligence questionnaires (DDQs), one increasingly common question is, “does your firm block access to data sharing sites such as DropBox or Google Drive?”
Generally the answer to this question should be ‘Yes,’ but that isn’t always the case because public file sharing services such as these are very convenient, and firms may overlook the security risk they pose. Additionally, employees accustomed to using Dropbox for personal use may be tempted to go for convenience over security when they need to share a large file or data set.
However, with security threats multiplying exponentially, hedge funds and alternative investment firms need to be proactive in protecting data and personally identifiable information (PII) from accidental and malicious insider risks. That’s why for secure file sharing Eze Castle Integration includes Varonis' DatAnywhere product as a standard feature within our Eze Managed Suite. Varonis' DatAnywhere offers users seamless and secure collaboration and file sharing across devices.
Beyond security, Varonis' DatAnywhere is easy to use. Users receive the same drag-n-drop experience as shared network drives or a cloud sync folder, which means no need for training on complex user interfaces and collaboration workflows. Additionally, data is automatically backed up and version controlled.
Cloud, Cyber Security and Managed Services: Putting Eze Castle Over the Top in Waters Rankings (Video)
We're thrilled to share that Eze Castle Integration has won the coveted awards for Best Cloud Infrastructure Provider and Best Cyber-Security Provider in the 2016 Waters Rankings. Vinod Paul, Managing Director of Eze Castle Integration, spoke with Dan DeFrancesco, Deputy Editor of Sell-Side Technology and Waters Technology about how Eze Castle Integration differentiates itself from other cloud and security providers.
Watch Vinod's video interview below or scroll down for some quick takeaways.
A new year, which is just around the corner, brings us endless opportunities to improve. So here’s a list of the top 4 IT resolutions that will help keep your hedge fund safe and sound in 2016.
Eze Video Debut!
Ever wonder about the layers of security encasing our Eze Managed Suite solution? We thought you had. That's why we created this video, which outlines not only the security protections but also the extensive services available to investment firms and hedge funds that move to our premier cloud solution.
Watch, learn and then contact us for more details.
In the context of information technology, social engineering refers to the act of tricking people into divulging confidential or sensitive business information, and breaking security policies. This form of attack infiltrates companies by targeting their weakest access point, which predominantly is a firm’s employees.
The Art of the Phishing Con
Let’s examine a popular technique for social engineering known as phishing. In a phishing scheme, the hacker broadly disseminates a fraudulent email with aim to acquire sensitive data, such as, login credentials, IT resources or banking information. The message may request the recipient to submit personal information or to click on a link embedded with malware. Although this approach rarely dupes sophisticated users, a distracted employee could make one mistake and compromise a firm’s entire network.
In its 2015 priorities, the SEC’s Office of Compliance Inspections and Examinations (OCIE) listed cybersecurity as a key focus area in its risk-based assessments. Then on February 3, 2015, OCIE released summary findings from its Cybersecurity Examination Sweep.
OCIE’s sweep focused on written documentation for their assessment and conducted "limited testing" of the accuracy of the responses. They did not review the technical sufficiency of the firms’ programs either. OCIE’s reliance on documentation highlights the importance of complete Written Information Security Policies.
Following are noteworthy items Eze Castle Integration observed in reviewing the findings.
Most firms adopted written information security policies, but 43% of advisers did not conduct periodic audits to determine compliance with these information security policies and procedures.
49% of advisers did not discuss mitigating the effects of a cybersecurity incident and/or outline the plan to recover from such an incident in their written business continuity plans.
The vast majority of examined firms conduct periodic risk assessments, on a firm-wide basis, to identify cybersecurity threats, vulnerabilities, and potential business consequences. However, only 32% of advisers require cybersecurity risk assessments of vendors with access to their firms’ networks.
In the Written Information Security Plans (WISP) Eze Castle Integration creates for clients, we include service provider risk assessments as a standard element.
With a new year comes new regulations for hedge funds and investment firms. Earlier this week, Eze Castle Integration hosted a webinar during which Ricardo Davidovich, partner at Haynes & Boone LLP shared his insight into the Securities and Exchange Commission’s (SEC) new examination priorities as well as reoccurring themes firms should expect to see play out through the year.
What’s New in 2015
One priority for examinations this year is the focus on retail investors. Davidovich says that “hedge funds, which in [the SEC’s] mind have historically been an exclusive and private club, are being sold to the retail and consumer client base.” Meaning they will be taking a closer look at the types of fees being sold, the sales practices and the suitability analysis. Firms should focus on making sure no information released is misleading and that there are provisions against fraud. There should be a real emphasis on policies to create guidelines that can be shown and proven to the SEC.