October marks Cybersecurity Awareness Month, a timely reminder that protecting client and firm data isn’t just an IT initiative, it’s a compliance responsibility. For financial firms, cybersecurity breaches can result in regulatory scrutiny, reputational harm, and costly penalties.
To help your compliance team stay proactive, here are five concrete steps to strengthen your firm’s cybersecurity compliance program:
1. Conduct Periodic Access Control Audits
Why it matters: Unauthorized access is one of the most common root causes of data breaches. Regulators expect firms to demonstrate that access rights are properly assigned, monitored, and revoked when employees depart.
Action Step:
Establish a quarterly access review led by compliance, in partnership with IT. Verify that:
- Multifactor authentication (MFA) is enabled firmwide
- User roles match current job duties
- Departed employees’ accounts have been promptly deactivated
- Access logs and audit trails are retained for regulatory review
Recommended Courses:
- Customer Data Protection — Course #17699
- Identity Theft Prevention and the Financial Services Industry — Course #17731
2. Formalize and Test Your Data Protection Program
Why it matters: Protecting client data is a fiduciary duty under both SEC and state privacy expectations. Inadequate data governance or outdated retention practices can trigger major compliance violations.
Action Step:
Develop or update your Written Information Security Program (WISP) to clearly outline how client information is collected, stored, encrypted, and destroyed. Then, test those controls annually through compliance-led reviews or tabletop exercises. Ensure encryption policies, retention schedules, and breach notification procedures align with Regulation S-P.
Recommended Courses:
- Privacy, Confidentiality, and Information Security — Course #17752
- NEW! Cybersecurity Essentials for Investment Advisers — Course #25032
3. Launch an Ongoing Cyber Awareness Training Program
Why it matters: Regulators have repeatedly emphasized that human error, particularly phishing, is a firm’s greatest cybersecurity threat. Annual “check-the-box” training is no longer enough.
Action Step:
Implement a rolling cybersecurity awareness campaign with quarterly touchpoints. Include simulated phishing exercises, short scenario-based videos, and reinforcement of incident-reporting protocols. Track participation and comprehension to demonstrate training effectiveness during exams.
Recommended Courses:
- NEW! Cybersecurity and Cyber-Enabled Fraud — Course #25031
- Cybersecurity: Phishing — Course #17707
4. Map Your Firm’s Controls to Regulatory Expectations
Why it matters: SEC and FINRA exam priorities consistently list cybersecurity oversight as a top focus. Firms must show regulators that supervisory systems adequately address technology and data risks.
Action Step:
Perform a regulatory alignment review at least once a year. Map your Written Supervisory Procedures (WSPs), testing, and vendor oversight to current guidance from the SEC’s Division of Examinations and FINRA’s exam priorities. Document your findings, assign ownership for gaps, and maintain an evidence file for exam readiness.
Recommended Courses:
- Cybersecurity & FINRA — Course #17702
- Cybersecurity: Modern Regulatory Resources and Case Studies
5. Build and Test Your Incident Response and Vendor Oversight Plan
Why it matters: When a breach occurs, regulators assess how well your firm planned, responded, and communicated. Vendor failures often become your firm’s compliance failures.
Action Step:
Establish a cross-department incident response plan that defines escalation roles, timelines, and client communication steps. Conduct annual tabletop exercises to test it. In parallel, evaluate third-party vendors by reviewing cybersecurity certifications, due-diligence questionnaires, and contract clauses requiring prompt breach notification and minimum security standards.
Recommended Courses:
- Cybersecurity for Supervisors — Course #10698
Final Thoughts
Cybersecurity compliance is not just about technology. It’s about demonstrating control, oversight, and readiness. By turning policies into repeatable actions and pairing them with ongoing training, compliance teams can strengthen both their firm’s defenses and their regulatory posture.
Explore Quest CE’s Cybersecurity Course Catalog or connect with one of our experts to learn how to build a robust, exam-ready cybersecurity program.
