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12.01.2014
The subject of hedge fund operational due diligence is one that has risen to the forefront for both hedge fund managers and investors in recent years. Historically, there has been a general lack of transparency within the hedge fund industry; larger funds, in particular, often balked at investor inquiries.
Due diligence, as a process, did not gain significant importance until just a few short years ago.
Hedge funds managers and investors are now taking due diligence seriously and making conscious steps to maintain open communication and increase information-sharing. Operational excellence has become one of the most important factors to hedge fund investors today as they determine where to allocate their money. What service providers are you engaged with and how do you determine their quality of service? Investors need to understand why hedge funds have made each of their operational choices, including when it comes to technology. Investors have become much more aware of technology and how important a role it plays in the day-to-day operations of a hedge fund.
Hedge funds should be prepared to recover from both short- and long-term disasters and be prepared to outline their processes and procedures (in writing!) to investors. Hedge fund operational due diligence is an opportunity and a marketing exercise – one that funds should undertake with educated personnel and a willingness to be open and transparent.
Show investors that you have a 3+ year budget for working capital without any performance fees.
Make sure to properly allocate expense and investment opportunities if you decide to launch a single investor fund or separately managed accounts. When it comes to seed arrangements, pick the right partner and put parameters around potential issues that could arise. Become familiar with the changing expectations on the cybersecurity front, from both investors and regulators. The Cybersecurity Interpretive Notice applies to all membership categories--futures commission merchants, swap dealers, major swap participants, introducing brokers, forex dealer members, commodity pool operators and commodity trading advisors. But whatever approach is taken, the Cybersecurity Interpretive Notice requires Members to adopt and enforce an information systems security program (ISSP) appropriate to its circumstances.
Description of ongoing education and training related to information systems security for employees. NFA recognizes that some Members may face a significant challenge implementing ISSPs by the March 1, 2016 effective date, and any programs that are adopted will be refined over time.
Eze Castle Integration’s Cybersecurity Practice Team is available to create Written Information System Security Programs for firms. Operating capital may be limited in the first few years after your launch, so careful budgeting and long range planning will serve your firm well. Governmental oversight of the financial industry has evolved dramatically in the last decade. Apart from registration, you should also determine if there are any legislative implications for your new firm. Since 2014, cybersecurity preparedness is also a critical area of focus for regulatory bodies. Cloud services offer more flexibility than traditional infrastructure models and, beyond cost-savings, can reap rewards for new launches.
Of course, one of the greatest benefits to using an outsourced cloud service is professional management and monitoring.
Beyond infrastructure safeguards, it is critical that firms implement policies and procedures to protect firm and client assets.
While the list of considerations is surely long for new hedge fund managers, we've whittled it down to 10 Keys to Launching a Hedge Fund Successfully - a guide for new startups to use when setting off on their new journey.
We at Eze Castle Integration have identified the top four reasons why backups are critical to not only a firm’s growth, but also their survival. The Securities and Exchange Commission (SEC) has instituted regulations on the storage of financial records and electronic communication, and financial industry regulatory agencies such as FINRA now provide standards and guidance information on potential threats.
The reasoning behind these recommendations is the volume of things that can go wrong with your data storage solution. Regulatory and compliance organizations recognize the necessity of data security and advocate for firms to have a comprehensive backup solution in place. As reported by Gartner in the 2015 Gartner MQ Report for Enterprise Backup Software and Integrated Appliances, by 2017, the number of enterprises using the cloud as a backup destination will double, growing from twelve percent (12%) today. Consider the impact to your business if you lost the data held in your CRM, financial, or reporting systems. Backups should be an integrated part of not only the IT department, but of the overall business strategy.
Businesses invest large amounts of time, money and resources into their operations; however, most are lacking a plan to protect this hard work. Because the security of data is imperative, it’s critical that firms choose the right provider to maintain tight control and visibility over business critical information. Communicate – It is important to let your employees know as soon as possible that they will no longer be able to get to work.
Technology – Technology has facilitated the ability for an employee to work remotely during a storm, but there are still some considerations to think through. Hunker Down –During severe storms employee safety should be at the top of the priority list. Set Workload Expectations – As an employee, a storm can be disruptive to their normal work day. Updates – As a consistent theme throughout BCP, communication is key, and continued updates will keep the employee centered on their work and allow them to respond to changes quickly such as the reopening of the office building. The key to a successful business continuity plan lies in understanding the impact a disaster situation could have on a business and creating policies to respond to any such impact.
The final critical element of a BCP is ensuring that it is tested and maintained on a regular basis. Or contact Eze Castle Integration to speak with one of our certified business continuity planners about best practices or to learn about why leading hedge funds rely on Eze Business Continuity Planning Services.
We spend a lot of time educating our clients about security best practices and encouraging them to implement comprehensive security policies and procedures to mitigate risk and protect both the firm and its employees. While companywide policies should reflect long-range expectations and corporate best practices, they should also include tactical recommendations that employees can follow to ensure they are complying with the company’s overall risk strategy.
Provide information such as login IDs, passwords, social security numbers, account numbers, etc. It is no surprise that the investment industry landscape is becoming more and more competitive. A comprehensive DDQ covers a wide range of topics, from assets under management to audited financial statements and investment strategies.
So, to help you get started, we have compiled the following list of some frequently asked DDQ questions. Does the firm have established, documented service level agreements in place with its technology partners to ensure a stable computing environment?
Is the policy regularly reviewed to determine whether the controls are operating as intended? Do the appropriate management officials approve the policy and any changes that may be made? Does the firm’s IT staff (or technology partner) ensure appropriate access control to applications and sensitive company data? Is a solution in place to ensure mobile devices and laptops are secure in the event of loss or theft? Has the firm established a dedicated location to retain backup copies of all critical data?
Has a secondary working location been established to which employees should report in the event of a disruption or outage? Is a comprehensive disaster recovery solution in place to provide system redundancy and ensure protection of critical data in the event of a disaster or system failure? Has the firm determined its crucial recovery point objectives (RPOs) and recovery time objectives (RTOs)?
Resolution 2: Conduct a Security Assessment or if you rely totally on a cloud solution, make sure your provider has conducted a recent vulnerability assessment and request a copy of the report. Resolution 4: Ensure Your Business Continuity Plan (BCP) and Written Information Security Policies (WISPs) are current and accurately reflect your business operations and the evolving risk landscape. These factors may seem to support the belief that public clouds and free file sharing services would suffice for a business’s basic infrastructure and file sharing needs. While there are several popular services which enable file sharing among small groups of people, they are not easily scalable to support small businesses, and can quickly become clumsy and inefficient as the firm grows.
While some free public cloud services are slightly more robust, these tools are not nearly as feature-rich as a dedicated private cloud system and are much more challenging to integrate with other systems or applications.
Additionally, most free public cloud tools do not support integration with CRM, OMS or other third-party systems which firms will require as they grow. For investment management firms, uptime is crucial to operational efficiency and profitability. Having a comprehensive disaster recovery solution in place helps protect your fund’s data as well as its reputation.
Institutional investors will likely not be comfortable having their information shared via a public file sharing service. The financial services industry continues to face compliance pressures and increased regulation. Comprehensive enterprise private cloud services can easily integrate with archiving tools to help ensure that all emails, IMs and attachments are indexed and easily retrievable. A component of Disaster Recovery that deals with the restoration of business system software and data, after the operating system environment has been restored or replaced. A pre-identified group of individuals that is reponsible for maintaining and executing the recovery process.
A system of planning for, recovering and maintaining both the IT and business environments within an organisation regardless of the type of interruption.
A collection of information on a wide range of areas from recovery assumptions and critical business processes to interdependencies and critical staff that is then analysed to assess impact a disaster may have. The process of restoring and maintaining the data, equipment, applications and other technical resources on which a business depends.
A disaster recovery hot site is a remote physical location where you can maintain copies of all of your critical systems, such as trading applications, data, and documents. A computer system or application that is essential to the functioning of your business and its processes. In the context of a primary and secondary site, the primary site contains the original data that cannot be recreated. The RTO is the duration of time and service level within which a business process must be restored after a disruption in order to avoid unacceptable losses. The RPO is the point in time to which a firm must recover data as defined by the organisation. A system of using multiple sources, devices or connections so that no single point of failure will completely stop the flow of information. The identification and prioritisation of potential business risk and disruptions based on severity and likelihood of occurrence.
The secondary site contains information and applications that are built from the primary repository information.
If regular testing is a critical component of an effective DR solution, why do many firms fail to do so? Here at Eze Castle, we strive to educate our clients on different testing methods so that they find an option that best meets their unique business requirements. As we continue to educate our hedge fund and investment firm clients on disaster recovery testing methods and the available options, we have seen a drastic increase in the number of clients that elect to implement regular testing procedures. A: Users should verify that they have the functionality needed to work successfully from the DR site during a disaster. A: If a firm fails to test its DR systems, they run the risk of the DR site not meeting current business requirements during a disaster. Q: Will testing our disaster recovery site disrupt our production site (and therefore normal business operations)? Business continuity is back on the agenda, as companies recover from a year of snow, ash clouds, and snow again. Severe weather, flu pandemics, power failures and transport chaos: events that disrupt a business come in many guises.
However, despite the clear dangers, only around half of all businesses are said to have a business continuity plan, and even fewer have one that can really be considered effective.
Stuart Hotchkiss, author of the recent BCS book Business Continuity Management: In Practice, believes the problem goes deeper. This lack of preparation comes despite evidence that disruption can be fatal to a business.
As Forrester Research points out, one reason for low levels of preparedness is that it can take a headline-grabbing disaster to force boards to pay attention to business continuity. For IT departments, though, it is vital to recognise that a good business continuity plan has both IT and non-IT elements.
To do this, IT departments can turn to technologies such as remote and mobile working and, increasingly to cloud-based services, from simple online backups or Google Apps to more complex systems employing cloud infrastructure to store data remotely and run backup copies of applications. Good communications management is also essential: companies need to ensure that they can circulate alternative email addresses and contact numbers of key personnel, and that staff working on a Plan B can connect to backup services, for example if the main VPN or datacentre is down.
The fact that good continuity measures go beyond IT recovery plans emphasises the need for IT to be part of a multi-disciplinary team.
Then, the project planning team needs to look at the organisation's business processes, to see which need protecting or replicating.
Forrester calculates that business continuity and disaster recovery should account for six to seven per cent of IT budgets. Stuart Hotchkiss' Business Continuity Management: In Practice is available from the IT PRO bookstore. When preparing to implement an EMR or EPM system with a graphical user interface, your entire staff will need to possess at least some computer skills.
Some staff members will need to be able to check patients in and out; others will have to post money or generate claims. The electronic medical records committee must design a training plan which takes the above factors into consideration. CCHIT had been given an (un)official nod from the government's Office of the National Coordinator for Health Information Technology as the certifying body for EMR standards.
At our practice, mind-mapping software has become indispensable for managing projects of any size. I've successfully rid the home office of paper records by scanning them all - then shredding them. Many computers have monitor or video out-ports which allow a connection to a second monitor. Although no single device can do it all, I have discovered a PDA or smart phone to be especially useful. Some recent legal cases have established that data which is accessible must be able to be produced, including backup. In the world of paper records, charts that are more than seven years old that were purged are considered legally inaccessible.
Eventually, rational minds emerged victorious, and some of the more inane regulations have relaxed somewhat. Consider forming a Legal, Risk & Compliance (LRC) Committee for your practice, to address the above-mentioned issues and others which may arise.
At the heart of authentication is controlling access to ensure individuals only access the information they need. As part of Information Security Planning, firms should also identify applications, services or websites that require at least one level of authentication (e.g.
Knowledge based, which centers on something you know such as a password or answer to a security question.
Possession based, which is linked to something you have such as a cryptocard, mobile device or ATM card. Speaking of a second authenticator, multi-factor authentication is established by requiring two of the above factors. Putting a specific two-factor authentication product in the spotlight, Eze Castle Integration has added Duo, a two-factor authentication tool, to our Eze Managed Suite offering to provide an added layer of security and protection. With Duo, users leverage their smartphones for authentication, eliminating the need to carry extra devices, like tokens, fobs and key cards. But there is another trap you should be wary of, and that’s the one hackers are setting for you right now.
A cyber attacker will send you a message that appears to be from a reliable source, prompting you to open it.
In traditional phishing, cyber criminals send out messages to millions of users trying to infect as many users as possible. Many firms create a 10-20-page written information security plan that formalizes the definitions and policies that govern the creation, access, and deletion of confidential information and computing services.
Regulatory Risks – Following the right security practices will enable you to achieve clean audits from industry and government regulators. Personal Email – Even if your employee is following all of your processes and practices with work-related email, you could still be vulnerable if her private, personal email is breached or corrupted. By developing an internal culture of security, the organization does far more than deploy and configure bits and bytes.
The cybersecurity landscape is constantly changing and today the cyber threat actors range from organized crime to state sponsors.
When it comes to advanced persistent threats, the cyber criminals often use targeted social engineering tactics including spear phishing.
Real-time intrusion detection and prevention systems that include 24x7 monitoring by security experts are a key defense in finding and stopping network intruders.
In some cases, however, insurance coverage has not satisfied the demands of firms and instead left them feeling scammed a second time. One example of this comes from Texas where a manufacturing firm is suing their cyber insurance provider for refusing to cover a loss that came at the hands of a phishing scheme. Situations like these are reminders for Chief Financial Officers and Risk Officers to carefully comb their cyber insurance policies to gain a comprehensive understanding of what exactly is covered – and what is not. Given the risk landscape, it is no wonder companies of all sizes continue to be subject to increasing data breach liability, both in the form of single plaintiff or class action lawsuits and regulatory investigations and proceedings. Plaintiffs in data breach class actions typically allege that businesses failed to adequately safeguard consumer information and gave insufficient and untimely notice of the breach.


Companies affected by a Cyber breach may also face liability to third parties, which may result in defense costs, settlements, judgments and, sometimes punitive damages. It seems that every hour emerging innovations and dynamic social platforms open the threshold of new opportunities to share and attain information. When it comes to social media engines, when did people become the mindless machines pumping out sensitive information? Think of other websites you frequently utilize that require passwords and personal details. We select these Q&As to safeguard our personal accounts, but overlook other platforms we might have shared this information on previously. The Internet of everything is so interconnected these days that it seems routine to grant access from one outlet to the other. Additional recent hacks include video gaming site Twitch, toymaker VTech and the latest, open source tool Socat. Marc Berger’s opening statements emphasized the extent of the cybersecurity threat currently facing firms across a wide swath of industries.
Where there is reliance on third-party service providers, the AAM is NOT relieved of its cybersecurity risks but rather, has the obligation to assess and monitor the provider’s security policies and procedures and conduct adequate due diligence.
While the SEC has issued various Risk Alerts providing guidance on areas of focus, the guidance and rules are not prescriptive.
Only 39% agree that their organization has ample resources to ensure all cybersecurity requirements are met. Last year, cybersecurity took center stage across the investment community, and there is little doubt that it will continue to dominate in 2016. Previously a non-factor for hedge funds, marketing is now a critical element to any firm’s success.
One trend that we noticed in 2015 that we may see extend into the New Year is the transition some hedge funds are making into the family office spectrum.
The Securities and Exchange Commission took major strides to regulate investment firm cybersecurity practices in 2015, with the release of multiple guidance updates (Click for the September 2015 update).
In December 2015, we participated in a Wells Fargo Prime Services cybersecurity event and the panelists outlined everything your hedge fund needs to know about the SEC’s security expectations. As referenced above, training is critical to showcasing cyber preparedness in today’s world. One final article related to security hones in on the fifth bullet above – vendor management.
Prior to the economic downfall in 2008 and high-profile investment scandals made infamous by Bernard Madoff and others, hedge fund due diligence was viewed as an unnecessary assignment. They figured there would never be a shortage of investors, so there wasn’t a need to spend extra time satisfying their needs. In the past, the responsibilities associated with hedge fund due diligence would often fall under the role of a CFO, CCO or other executive – someone who had very little time to devote specifically to due diligence. There has, undoubtedly, been a significant increase in the number of due diligence inquiries by hedge fund investors, and the questions they are asking are much more relevant and involved - that rings true across business and operations functions, technology departments and the investment side of the business. They want more information, more transparency and more assurances that fund managers have done their own due diligence in assembling and managing their infrastructure and overall businesses. Small-scale disasters, such as winter weather scenarios, and larger incidents like the Madoff scandal have initiated a real shift in the hedge fund industry and highlighted the need for hedge funds to have robust technology solutions in place and systems and procedures to keep them operational at all times. During the due diligence process, they often ask to see systems at work, the processes through which data is transmitted and stored, and how testing procedures work. Explain the designs and processes of your operations, particularly when it comes to your technology.
If you do not have an in-house IT staff, you can ask your technology service provider to do this for you. You will score points with investors if you are up front about everything and don’t attempt to hide anything. Hire a consultant to help you with this – it is the single easiest way to prepare for a real investor review. Test your disaster recovery system frequently (at least twice annually), and show the results to investors.
Investors want to see that funds are serious and that they value operations and technology as vital aspects to their businesses. It does not begin when an investor comes in for a meeting and end when they walk out the door. Not only must emerging managers evaluate traditional deployment strategies, but consider current factors influencing the financial landscape. There was quite a bit of content discussed during the 1-hour event, so we’ve pulled out some key takeaways. Target those who have a history of being receptive to founder share class and who may offer lower management and performance fees. Recognize where the private cloud has an edge: high-touch, industry-specific service and support, scalability and application integration, and security and compliance. Value is derived from knowledge of the application, knowledge of business, and having a dedicated support team. The NFA's Interpretive Notice to NFA Compliance Rules 2-9, 2-36 and 2-49 entitled Information Systems Security Programs requires Member firms to adopt and enforce written policies and procedures to secure customer data and access to their electronic systems.
Executive-level participation and annual review of the information security program is expected. NFA expects to devote appropriate resources, such as providing additional guidance, to assist Members as they develop and implement their ISSPs. Don't forget to visit Hedge IT on Thursday as we reveal the last of our key considerations for starting a hedge fund. Hedge funds, private equity firms and registered investment advisers now operate in a world where they are beholden to regulatory bodies with growing expectations and requirements. The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, which redefined the registration requirements for hedge funds, also set forth new reporting requirements and standards for safeguards. With the prevalence of cyber threats and attacks, the SEC’s Office of Compliance and Examinations (OCIE) has incorporated cybersecurity into its examination targets. Firms can add users nearly instantly – a welcome benefit for startups looking to ramp up quickly. You can do this by conducting employee awareness training to keep all users informed and educated about the cyber environment and the threats that may arise. And be sure to come back to Hedge IT later this week when we'll be sharing an excerpt from our brand new whitepaper on the same topic! Regulatory agencies and investors now expect businesses to have backup solutions and comprehensive record-keeping practices.
In addition, international regulators such as the FCA, a financial regulatory body in the United Kingdom, are also demanding firms to have a data backup solution. From hardware failure, software corruption, virus or network security breaches, to natural disasters and human error, the threat to your data is endless. Businesses that demonstrate that their data is secure and backed up have a competitive edge when security questions inevitably come their way. And by 2017, seventy-five percent (75%) of organizations will have replaced their remote-office tape backup with a disk-based backup solution that incorporates replication, up from forty-five percent (45%) today. A SMB Disaster Preparedness Survey by Symantec found that downtime costs small businesses an average of approximately $12,500 per day and medium businesses $23,000 per day. Eze Castle partners with KeepItSafe, a leading provider for managed online backup and recovery, to deliver our Eze Vault services. For example, what exactly will your employees need to fulfill their functions remotely and are they trained to do so? Therefore, if the storm seems to be impassable it is best to allow employees to work remotely. In addition to providing employees with security best practices they should follow, don’t forget to also include a list of actions they should not. Over the past few years, as regulations have changed and investors increasingly seek transparency, hedge funds are spending more time than ever preparing for the due diligence process. As this trend continues, investors are raising their expectations and looking towards hedge funds that display the highest levels in operational excellence. One major area of focus is the hedge fund’s IT and accompanying cybersecurity policies and procedures. Are steps being taken to ensure visitors do not have the ability to observe or access sensitive employee systems and documents? Have appropriate training and documentation been established and shared with all personnel? So here’s a list of the top 4 IT resolutions that will help keep your hedge fund safe and sound in 2016. Everything and everyone is going cloud so take some time to explore what a cloud solution could bring to your firm. The goal here is to gauge the level of security in place to protect against external threats and cyber-attacks.
With investors and regulators asking to review these polices, they are no longer just nice-to-haves. Because infrastructure costs are spread across all users who are employing the service, each individual client is able to operate at a low cost. However, upon closer examination, it is clear that there are a number of areas in which these tools fall drastically short of meeting the crucial business needs of investment management firms. Once your firm expands to the point of requiring additional applications such as a CRM, OMS and accounting tools, a free file sharing provider’s capabilities will no longer be enough to support your needs. For instance, although Gmail or Hotmail may be able to handle basic email needs, they will not provide the full business email experience as is attainable via Microsoft Exchange, and they are lacking many of the features and capabilities that Exchange provides. They also lack integrated voicemail capabilities, which means users cannot manage voice messages easily from their PC.
Free public cloud services are not accompanied by dedicated, vertical-specific IT support that is incorporated with quality private cloud infrastructures.
It also instills confidence with investors and other stakeholders while providing a competitive advantage. These tools have earned a negative perception due to their lack of effective security precautions. In addition to the IT infrastructure, it covers people, facilities, workplaces, equipment, business processes, and more. High availability can be implemented into a firm's IT infrastructure by reducing any single points of failure using redundant components. In working on the Eze Disaster Recovery team, I have heard a variety of reasons from clients as to why this is the case. Current technologies allow IT providers to overcome just about any objection users may have with regards to DR testing. We often find that firms grow, evolve, and change their production environments as they develop and expand their businesses.
At Eze Castle, we typically recommend that users think about their daily workflow when testing to help ensure all critical applications and data are available in the event of an outage.
Typically, DR solution agreements will include regular testing as part of the service package, and we strongly recommend all firms take advantage of this component. However, the reality is that many disaster recovery solutions (including Eze Castle’s!) can be tested in a manner that avoids any disruption to the production environment. Even just a few moments of downtime could be extremely costly, so it is essential that firms implement sound business continuity procedures. But creating a good continuity plan neither just about planning for disasters, nor a task for IT alone, says Stephen Pritchard. Bharat Thakrar, the global head of BT Global Services’ business continuity portfolio, puts the percentage of companies with that have a BC plan at 48 per cent, with the figure for SMEs “even lower”. According to research carried out by RISE, a cloud-based provider of data centres, which recently launched a business continuity service, 20 per cent of companies will suffer an outage. But there are other ways to focus directors' minds on the issue, including the risk of falling behind competitors – who will be more attractive to customers and more profitable if they suffer fewer failures – and the pressure of industry regulation. For Magnus Leask, IT director of Fast Track, a sports marketing company that runs events such as the Aviva UKA (Athletics) Grand Prix, the cost of continuity planning is low, when set against the cost of lost business.
Conventional, IT focused disaster recovery keeps systems running, but does little, for example, to help employees caught out by the weather. Few organisations will be able to protect all their processes, systems or applications to the same degree. Businesses need to test both the practicalities of their BC arrangements – can staff reach a recovery centre, do emergency communications work – as well as the technical recovery of IT systems and data.
But for IT directors who have had to deal with an outage, it is testing that can make the difference between survival, and failure.
Featuring expert guidance in electronic medical records, finance, administration and legal issues. However, a large percentage of adults still have limited experience with the latest technology. Maybe the technical staff won't have to understand the claims process, but they will surely need to be proficient using EMR. The committee will have to determine what the common tasks for every employee will be, then adding additional skills of increased complexity to the appropriate departments and jobs.
According to a report by FierceHealthIT, The Drummond Group, an interoperability testing lab in Austin, Texas, has thrown its hat into the ring.
An organization made up of industry experts, corporations, and other volunteers, CCHIT has also had its share of critics who charge that it is giving preferential treatment to big players in the EMR software community.
The ScanSnap 500 is a device which will scan everything, from PDF files to double-sided documents.
Many small, high-definition TV sets have a video in-port able to toggle between cable and satellite and a computer signal.
These devices are cell phones that run Windows apps, able to sync with Outlook on your desktop computer to access the Internet, email, and your contact list. No more can you even keep a patient check-in form at the front desk, or risk having a patient learn who else had been in on that day. Although this may seem an unfair burden for a medical practice, experts dealing with these sort of legal cases believe that EMR will result in a decrease of malpractice suits, owing to better documentation and a lower rate of medication-related mistakes.
There are still privacy issues which are specific to the electronic aspects of medicine, in regard to inappropriate disclosure of patients' data.
With stories of password compromises becoming more common it is important to understand the types of authentication factors available and good computing practices.
This is the most commonly used authentication factor and potentially the weakest if strong password and change requirements are not enforced.
When using a mobile device, for example, a one-time password (OTP) can be generated to provide access for only one login session or transaction.
Apple notably introduced inherence factor authentication with its iPhone TouchID biometric fingerprint reader.
This means that in addition to providing a password for access, a user would also need to provide a separate PIN number, for example.
Duo combines modern two-factor authentication with advanced endpoint security solutions to protect users from account takeovers and data breaches.
Phishing is a psychological attack used by cyber criminals in order to trick you into giving up personal information or taking action. If the email appears to be from a legitimate organization but the address is a personal account (Gmail, MSN, Hotmail, Yahoo) it is probably an attack. If your friend or colleague sends you a strange message, their account may have been attacked.
That can be everything from a definition of personally identifiable information (PII), a description of user access privileges and roles, or policies regarding USB thumb-drives.
It commits to defining and following thoughtful, far-ranging policies to eliminate the needless internal vulnerabilities that often go unrecognized.
APT intrusions are often focused on high-value information and sectors such as the financial industry.
In a spear phishing incident, criminals target specific companies or individuals and conduct background research to compile employee names, titles and contact information.
As hackers become savvier and cyber schemes more elaborate, many firms are relying on cyber liability policies to add an extra layer of protection. Governments are facing an unprecedented level of Cyber attacks and threats with the potential to undermine national security and critical infrastructure.
Negligence, breach of fiduciary duty and breach of contract are just some of the allegations that a company may face as a result of a systems failure or lax security that compromises the security of customers’ personal information or data. Companies may also face class actions from banks and credit unions seeking damages for administrative expenses, lost interest, transaction fees and lost customers. For example, 25 class action lawsuits were settled in the wake of a retailer’s 2007 data breach involving the theft of data related to over 45 million credit and debit cards. Third parties bringing lawsuits against businesses for damages are increasingly seeking to expand the nature of injuries and remedies sought in light of early case law which determined that there was no injury in fact sustained by the Cyber breach and thus no standing to sue. The enactment of ITERA and the growing recognition in the business community that time spent repairing credit may constitute an injury in fact, may create an increased willingness of courts to find consumer standing to bring such actions and thus an increased liability risk to businesses. Typical data requested from social sites may include your full name, age, sex, birthday, relatives, photos, account access, etc.
Conceivably, if you scroll through your status updates and photos on Facebook you could find all of these personal facts.
So routine in fact that cybercriminals have realized the window of opportunity presented by these information gold mines. The latter was announced earlier this week in a security advisory warning of a crypto weakness so severe that it may have been intentionally created to provide criminals a furtive means to eavesdrop on protected communications. Rather than being like Bill, we need to be more aware of the automaticity of our behaviors and tendency to trust sites while browsing the web.
As a result, firms are challenged to understand what level of cybersecurity readiness will be deemed sufficient to meet regulatory obligations given their AUM.
According to the Ponemon Institute’s 2015 Global Megatrends in Cybersecurity, sponsored by Raytheon, 25% of respondents in a study say C-level executives currently view cybersecurity as a competitive advantage, versus 59% who say it will be a competitive advantage three years from now.
In an industry historically known for protecting its information, recent regulatory developments may foster a change in how firms think about sharing information. Across the hedge fund and alternative investment industry, firms are devising new strategies and implementing plans to drive growth and increase returns.
If we can assume that firms used 2015 to shore up security practices and have, at minimum, established a baseline for protecting firm assets with firewalls, password protections and penetration testing, we can expect 2016 to take cyber preparedness to the next level in the form of advanced features and analytics including phishing and social engineering tests, designed to increase the level of preparedness held by firm employees.
In 2016, hedge funds and investment firms will need to develop comprehensive marketing strategies in order to elevate their brands, attract new investors and retain capital. Several prominent former hedge fund managers returned outside money in recent years and began operating as family office firms, most notably Steve Cohen and George Soros.


Instances of social engineering are often what trip up employees – think phishing and spear-phishing schemes.
Anytime an investment firm works with a third-party provider, it’s important to understand what risks become present and how firms can manage said risks. But as the hedge fund industry has evolved over the last several years, so has the need and desire for operational excellence.
You can also compile a comprehensive presentation or simply have an open question and answer session with your potential investors.
Due diligence is an ongoing process that can continue to improve and evolve as investors and fund managers open the lines of communication and maintain an open dialogue. Prepare an institutional set of documents up front if you are looking to attract institutional money versus high net money. They include risk assessment, governance, training, access control, vendor management, and information sharing. Additionally, firms must provide employees training during the onboarding processes as well as periodically during employment. For example, system safeguards such as data protection, disaster recovery measures and email archiving are requirements under Dodd-Frank. Having released two extensive questionnaires and several risk alerts focused on security, the SEC has made it clear to investment firms that they will be investigating the practices employed at firms and increasing expectations for the future.
Startups have a variety of options when it comes to settling on their technology infrastructure. Users can gain access to email, file services and applications from virtually anywhere, and built-in disaster recovery provides confidence that everything is protected from the inside out.
Users should understand how security threats may present themselves (phishing schemes, social engineering, etc.) as well as how they can become cybersecurity assets to your firm.
Successfully operating a new startup beyond the first year is a feat many managers struggle to accomplish, therefore it's critical for emerging managers to gain a full understanding of the industry that awaits them and the hurdles they should expect to face.
Understanding the need and importance of implementing a backup solution can add instrumental value to your business. With today’s financial services companies managing exponentially growing volumes of sensitive data, the risk of loss grows as well. If something were to happen to the data center where your production system lives, you can resume operations in DR. Having a third-party backup solution provides geographic diversity of data assets, which is key for a complete business strategy. Recently, KeepItSafe highlighted the success of a backup and recovery case when a company’s servers crashed, and with it, so too did their records of billing history, accounts receivable and accounts payable. With these unprecedented levels of snow, New York City was forced to halt public transportation and implemented a mandatory restriction on private transportation as well. One must also consider licensing, infrastructure, security, and employee comfort as working from home will be a change for them. If essential functions are unable to meet their workload demands from home, then temporary office space with redundant power is always an option. It is always important to review your business continuity plan and make sure employees are aware of their roles if an issue were to occur.
In today's landscape, however, investors and regulators alike expect and demand that firms implement preparedness plans for disasters and cyber-attacks. Take a look below and discover a vast range of security tips and tricks from email encryption to proper security measures for protecting computers and mobile devices. One important way to ensure your firm meets these high standards is to complete a due diligence questionnaire (DDQ) that can be shared with potential investors.
At Eze Castle, we frequently assist our hedge fund clients in completing DDQ questions on technology, and we often see the same types of questions popping up.
In addition, a great resource for conducting due diligence on a hedge fund's service providers is the 200 question document published by the Alternative Investment Technology Executives Club (AITEC).
From enhanced security and disaster recovery to resiliency and extensive application sets, a cloud solution may be a game changer for your firm.
It is not uncommon for firms to change their production environments as they grow and evolve, but it is critical that DR remains an exact mirror so users have a seamless experience should activation occur.
Beyond having Business Continuity and Information Security Plans, you also need to appoint a Chief Information Security Officer and have an incident response playbook. Public cloud tools are typically larger in scale than private enterprise clouds, which provide users with seamless, on-demand scalability.
While this tool may be suitable in helping your firm get off the ground with minimal upfront costs, it is not a viable long-term solution. In fact, several of these providers have experienced outages in recent years, some of which have lasted for hours or days at a time.
In a business setting, this could mean that sensitive company or client data is exposed externally. Public cloud tools may not include a built in disaster recovery solution, so this is a significant additional cost that your firm will have to consider. The SEC currently advises that funds retain all internal and external email and IM business communications, a perspective that is shared by the majority of investors as well.
Be sure to read our articles on the difference between DR & BCP and preparing for a worst case scenario. Additionally, we are hearing from a growing number of hedge fund clients whose investors now require them to test their DR solutions and report on the results from those tests. In turn, the DR site needs to evolve and change simultaneously in order to continuously meet business requirements.
Results should be documented and provided back to your DR provider so that they can assist you with resolving any issues that may have arisen during the course of the test.
Regular testing helps to capture the ever-changing requirements of a business, so that gaps or issues can be addressed in advance of a disaster. Of the remainder, half have out-of -date plans, which would never work in practice, and I would guess that only 10 per cent of companies do any kind of yearly testing,” he says. Of those that do not have a recovery plan 43 per cent will never re-open, 80 per cent will fail within 13 months and 53 per cent fail to recoup losses incurred as a result of the incident.
But an IT system that is prone to failure poses its own challenge to the business' operations.
An orderly system for recovering data and bringing applications and processes back on line should also be part of the plan, so that all employees know what is offline, and how quickly it is likely to be recovered. Only testing shows that the chain in command does work, and reveals where bottlenecks or vulnerabilities sit within systems themselves. It's a lucky fact that most doctors must keep with technological advances out of necessity.
The best part is that you don't need to be a computer genius to use these tools - they're intuitive, making projects easy to follow visually.
This application has modules to set up various goals, from business, to family, to personal. When you set up dual display with the TV as the second monitor, you can double the work area on the desktop. Some people use the phone connection to access the Web, while others connect through a wireless network.
Even so, if data is kept on a failed hard drive, and the costs of recovering the data is significant, it could create an undue burden; judges could rule that the expense be shared between the two parties. When it comes to electronic information, however, inaccessibility could be more difficult to prove, as electronic data can almost always be recovered. An unauthorized email, unsecured wireless network, a computer monitor left on in view of another patient are some prime examples. Firms should require passwords to be at least 12 characters in length, changed at least every 90 days, and not be reused. Another place this factor is common is for granting access to a data center – firms may want to use biometric screening as a second authenticator. Oftentimes the email domain will be missing a letter or have letters reversed, so you'll have to pay close attention. Also, hover your mouse over the link before you proceed to make sure that it is taking you where it claims to.
The bank believes hackers executed a hack that allowed $81 million to be taken from the bank’s foreign exchange account at the Federal Reserve Bank of New York. And the way that starts to happen is through systemic and comprehensive training practices. Similarly, businesses across a wide range of industry sectors, particularly those in the health care, retail and financial services industries1, are exposed to potentially enormous liability and costs as a result of Cyber incidents and data breaches.
Increased regulation at federal and state levels related to information security and breach notification is expanding the legal avenues that may be pursued. Behavior quizzes offer entertainment to discover your celebrity and fairytale doppelgängers, or breakfast food and ice cream personality matches. These sources generally ask us challenge questions as an additional level of security, such as, the make of our first car, hometown city, high school mascot or nickname. Criminals began creating faux, malicious versions of the app that asked users to sign into Facebook to generate their personal meme.
Highlighting the importance of information sharing, on December 19, 2015, after years of failing to enact cyber threat information-sharing legislation, Congress passed the controversial Cybersecurity Information-Sharing Act of 2015. In 2016, we expect the following industry trends will play a role in shaping many of the decisions hedge funds and other investment management firms make.
With cyber-attacks increasing in sophistication, firms will need to spend time in 2016 working with managed providers and internal IT teams to continue the education process and identify strategies to outsmart hackers. Whether via traditional marketing campaign tactics such as pitch presentations, websites and CRM systems or more modern avenues such as social media, firms would be wise to think through their objectives, plans, and communication methods before outreaching to potential investors. And while there are less regulatory pressures and expectations to meet as a family office entity, security measures should remain enterprise-level, and we expect to see family offices investing heavily in cyber preparedness policies and systems.
Hedge funds should continue to take the time to understand where the real risks are within their businesses and work to instill confidence with their investors. Regardless of the assets your firm is launching with, you will be expected to have sophisticated and comprehensive policies and procedures in place from day one to combat cyber threats. With the birth of cloud technology, firms can save on upfront capital expenditures and host their infrastructure in the cloud – providing flexibility within those startup budgets. A reputable cloud services provider not only provides world-class infrastructure and resiliency; it also assumes responsibility for the management and daily maintenance of your cloud environment. Investors also have high expectations, and before they will even consider allocating money to your firm, they want to understand what protections you’ve put in place to protect their assets.
However, if something is deleted in the production environment, that action is typically mirrored, thus deleted in DR as well. DR allows the rapid recovery of IT operations while cloud backups provide another layer of protection by leveraging a third-party vendor to secure your data in an alternative location. Jonas proved to be kind in the fact that the majority of the impact fell on the weekend but many firms can recall more disruptive storms occurring during regular business hours leaving many employees feeling stranded.
Just as importantly, if an outage does occur, there is no way to effectively communicate with an IT support expert to address and resolve the issue in a timely manner.
Also, because security measures are typically much more lax than with an enterprise-grade private cloud service, emails and other communications may be susceptible to interception by hackers. With a top quality private cloud infrastructure, disaster recovery is built directly into the offering and is seamlessly integrated to ensure your data is protected at all times. Public cloud and free email tools do not contain effective archiving and recovery capabilities, and could put your firm at risk of compliance violations should an issue arise.
This trend is putting more pressure on firms to participate in regular testing than ever before. By regularly testing their DR sites, firms can ensure all of these needs are met and they will be fully prepared to continue operations should a disaster occur. This requires less coordination with user groups, and therefore has minimal impact on the firm’s daily operations. For example, almost all of your employees will need to know how to use the system to look up appointment info. Next, the department should rotate through the training room to receive training on the necessary tasks for their particular jobs. Some newer versions such as Treo 150W can sync up with your contacts and calendar remotely from any location. In fact, most of the current EMR software systems don't even let a provider delete patient records. It appears that the initial point of entry for the hackers was a spear-phishing email, potentially sent weeks before the fraud took place, which allowed the criminals time to remotely monitor and probe the bank’s networks without detection. Obtaining such details and observing communications provides criminals with the tools to mirror email addresses, website URLs and dialect. More recently, in 2014, two major retailers reported that the total costs of data breach and related class action lawsuits (less expected insurance recovery) was estimated at $63 million and $191 million, respectively. In 2014, the agency issued a press release announcing its 50th Data Security Settlement on behalf of consumers. To partake in this social extravaganza, we hand over our personal information freely, forgetting its value somewhere between each hashtag and viral post. Through the app, users may customize their characters by simply providing their first name and gender on the Blobla website.
Once the criminals were logged in, they stole account details and infected computers with spyware, viruses and malware.
In this tug-of-war of security and connectivity, users can regain control of their personal information. As of June 30, 2015, per ITRC data, in 2015 the banking industry experienced an increase of 85% versus 2014 data for the same period. However, regulators may also be looking at whether enforcement action is warranted if the AAM failed to implement appropriate security measures that would have prevented the attack from occurring. Disaster recovery, business continuity planning and cybersecurity preparedness should all be viewed as full business exercises, not solely technology ones. Be sure to enable your firm’s processes to comply with SEC recommendations including risk assessments, infrastructure practices, policy documentation, etc. With hackers savvier than ever and financial firms as known targets, it’s critical that firms establish a comprehensive approach to security to not only meet investor and regulatory demands but also to protect firm assets and mitigate business risk.
Backups, on the other hand, create an offline copy of your data which is not accessible except to restore, sometimes utilizing a third-party vendor to store that data in an alternate location. The importance of protecting this data is interconnected to the importance of the overall operations of the business.
To alleviate the stress incurred during winter storms, we sat down with our own Business Continuity Analyst, Matt Donahue, who creates, writes, and audits hedge fund’s business continuity plans. As far as specific remote access technologies, Matt recommends Virtual Private Networks (VPN), Citrix or Outlook Web Access (OWA), depending on a user’s specific needs. These tests do not need to be elaborate, for example, a work from home day or a call tree run through might suffice.
With premier private cloud providers, your solution is accompanied by 24x7x365 help desk support equipped with the knowledge and resources to resolve technical issues quickly. Still, many other staff members have limited exposure to computers at work - and limited skill as a result. A manual was prepared for the EPM software module, and another is being written for the EMR module. A dashboard can handle your mind maps while helping to delegate the logistics of who, where, what and when of your projects. Although a bit larger and heavier than a regular cell phone, these devices make up for the added weight with increased flexibility. Phishing now refers to any message-based attack, whether that be email, IM, or on a social media network.
The end result is the criminal’s identity masqueraded as a legitimate, trustworthy source. And, this year, two major health care companies are separately facing several lawsuits as a result of data breaches that reportedly exposed the personal records of 80 million and 11 million people, respectively. One of those settlements involved the much publicized 2006 settlement with a data aggregation company wherein the company agreed to pay $10 million in civil penalties and $5 million in consumer redress for time customers may have spent to monitor and repair their credit following a breach that exposed their personal information. Federal laws, such as the Health Insurance Portability and Accountability Act, the Gramm-Leach-Bliley Act and the Fair Credit Reporting Act, have requirements to safeguard the privacy of personal information, and some states require notification to the state attorney general. Instead of dispensing reams of sensitive data, choose to keep what’s private, private. Firms can no longer act in silos, but must share information with industry peers (including competitors) to protect the entire sector.
If not forthcoming, you may open up your firm to serious regulatory and criminal prosecution. Your cloud services provider should act as your trusted technology adviser and, as such, give you the flexibility and time you need to focus on your investment priorities without worrying about security updates and patch controls. If access to a file was lost in both production and DR, backups grant the ability to recover the data and continue business as usual.
This is an example of a successful case; however, many businesses lacking a backup solution are not so lucky. Matt spoke with us about different BCP scenarios and provided tips to keep your firm operational during the worst of storms.
In order to gauge an employee's computer literacy, they can be asked about the applications they've used, and to give examples of the sorts of tasks they've performed. This has become a major area of law and will become increasingly important as EMR becomes the norm. While these matters have yet to be resolved, the anticipated costs of litigation and settlement may set records. Given this ever-evolving and regulatory landscape, companies should expect an increase in third-party liability claims led by federal regulatory agencies as evidenced by a March 2015 federal court decision involving a large hotel chain wherein the court held that the FTC has regulatory authority to enforce data security practices. Cyber-attacks carried out on the financial community have almost doubled in 2015, and industry experts believe these numbers will continue to increase unless adequate precautions and prevention measures are taken. AAMs can expect to see investors placing greater emphasis on cybersecurity as a part of its due diligence and regulators focusing on cybersecurity in their routine regulatory exams. It's also possible to tell an employee's competency through the vocabulary they are familiar with. The bottom line for medical practices is that a reliable and secure backup process is a must.



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