An Emerging Patchwork Of Cybersecurity Rules

By Michael Bahar, Susan Krawczyk, Ben Marzouk, Tony Ficarrotta and Issa Hanna (August 29, 2017, 11:11 AM EDT) -- With the recent adoption of cybersecurity regulations governing broker-dealers (BDs) and investment advisers (IAs) registered in Colorado and Vermont, the landscape of cybersecurity regulation continues to evolve in significant ways. For those businesses not yet covered by cyber regulations, these latest moves indicate that the day of reckoning may be coming, with both federal and state regulators actively expanding their reach.

Moreover, these latest regulations may further contribute to an emerging "cybersecurity standard of care," leaving those who lag behind best practices more vulnerable before the courts. Finally, this emerging regulatory patchwork increasingly threatens to lead to inconsistent  standards — although an...

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