State administrators float draft cyber rules update ahead of annual meeting

By Mark S. Nelson, J.D. The North American Securities Administrators Association issued a proposed model rule update dealing with cybersecurity for investment advisers. The draft documents began circulating as NASAA was set to kick off its annual meeting this week in Anchorage, Alaska, which also coincides with the installation of NASAA’s 101st president, Michael Pieciak of Vermont, who has announced plans to emphasize cybersecurity and related financial technology issues during his tenure. Public comments on the cybersecurity proposal are due by November 26, 2018. Update follows common cyber approach. The model rule update would clarify that investment advisers must maintain written physical security and cybersecurity policies and procedures that are reasonably designed to ensure the confidentiality, integrity, and availability of physical and electronic records and information. The CIA approach (confidentiality, integrity, and availability) is one of two foundational…

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