Advisers don't have to report everything that happens to the Securities and Exchange Commission or Financial Industry Regulatory Authority Inc., but they need to abide by the rules set by the state where they and their clients work and reside — and those rules can vary. Advisers should be aware of these policies while keeping track of any incidents as a precaution, experts said.
Advisor Armor Partner Sid Yenamandra, chief executive of Entreda, a cybersecurity and risk-management company, suggested that advisers create an incident log, whether big or small.
"It doesn't matter the scale of the issue, because it is oftentimes the littlest things that become some of the biggest problems later," Mr. Yenamandra said.
After the log is created, a third-party vendor or expert should ascertain the priority of each issue to determine the next steps. In some cases, the breach should be reported, but in other cases a firm only needs to draft a plan to avoid a re-occurrence, he said.
"The rule of thumb is any time there is a kind of account that has been compromised that could have revealed personally identifiable information data for one client or more than one client, that for us is when the eyebrows start to go up," Mr. Yenamandra said. MORE