Tag Archives: practices

Advanced Cyber Security Center Panel Explores Reasonableness in Cybersecurity

I had the pleasure of moderating an excellent panel at the Advanced Cyber Security Center’s annual conference on November 4. The panel’s topic for discussion was “What is Reasonable in Cybersecurity: Responsibility and Accountability for Cybersecurity Practices.” I learned a great deal from our excellent panelists, Gus Coldebella (Fish & Richardson), Deborah Hurley (Harvard University), and John Krebs (Federal Trade Commission), as well as from the audience’s questions.… More

CFTC Approves NFA Interpretive Notice on Information Systems Security Programs, Including Cybersecurity Guidance

By Catherine M. Anderson and Kate Leonard

The CFTC recently approved the National Futures Association’s interpretive notice (the “Cybersecurity Notice”) on the general requirements that members should implement for their information systems security programs (“ISSPs”), which includes cybersecurity guidance and ongoing testing and training obligations.

The Cybersecurity Notice will be effective March 1, 2016 and applies to futures commissions merchants, commodity trading advisors,… More