Financial Services Cybersecurity Counsel

When Examiners
Arrive, You Will
Be Ready.

Iron Bridge advises registered investment advisers, broker-dealers, and financial institutions on satisfying the cybersecurity obligations of NYDFS Part 500, the SEC's cybersecurity rules, and FINRA examination standards.

Regulatory Coverage
  • NYDFS 23 NYCRR Part 500 Active
  • SEC Rule 206(4)-9 Active
  • SEC Regulation S-P Active
  • FINRA Rules 4370 & 3110 Active
  • NIST Cybersecurity Framework 2.0 Active
$4.5M
Largest NYDFS Part 500 enforcement action to date. Fines are no longer theoretical.
72hrs
NYDFS notification window for a cybersecurity incident. Most firms are unprepared to meet it.
~1in 3
FINRA exams cite a cybersecurity deficiency. It is consistently among the top findings.
Regulatory Landscape

The Frameworks
That Govern Your Firm

Financial services firms face overlapping, evolving cybersecurity obligations. We help you understand what applies, where your gaps are, and how to close them before an examiner does.

Regulation
Overview
Key Requirements
NYDFS
23 NYCRR Part 500

New York's cybersecurity regulation applies to all entities licensed under the Banking Law, Insurance Law, or Financial Services Law. Amended in 2023 with significantly heightened requirements — enforcement is active.

  • Designated CISO with board reporting
  • Annual penetration testing
  • Multi-factor authentication
  • 72-hour incident notification
  • Annual compliance certification
SEC
Rule 206(4)-9 & Reg S-P

The SEC adopted sweeping cybersecurity rules for investment advisers in 2023. Rule 206(4)-9 requires written policies, risk assessments, and governance. Reg S-P was amended to add breach notification obligations.

  • Written cybersecurity policies & procedures
  • Annual risk assessment
  • Vendor & service provider oversight
  • 30-day customer breach notification
  • Books & records for compliance
FINRA
Rules 4370, 3110 & Exam Priorities

FINRA does not have a standalone cyber rule, but consistently identifies cybersecurity as a priority area in annual exam findings. Rule 4370 mandates business continuity plans; Rule 3110 requires a supervisory system that includes technology controls.

  • Business continuity & disaster recovery plan
  • Written supervisory procedures for technology
  • Access controls & privileged account management
  • Annual cybersecurity training
  • Third-party vendor risk management
Practice Areas

Services
Tailored to Regulated Firms

We deliver the senior-level expertise your firm needs, without the overhead of a full-time hire. Each engagement produces tangible, examiner-ready work product.

I

Regulatory Gap Assessment

A structured review of your current security program mapped against NYDFS Part 500, SEC rules, or FINRA requirements. Delivered as a written report with a prioritized remediation roadmap your board can act on.

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II

Fractional vCISO

Ongoing strategic leadership on a monthly retainer. Board-level reporting, vendor risk oversight, annual certification preparation, and exam defense — without the cost of a full-time executive.

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III

Policy & Procedure Development

We draft the written policies your regulator expects — information security policy, incident response plan, vendor management program, and annual review cycle. Built for your firm, not adapted from a generic template.

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IV

Incident Response Readiness

Tabletop exercises, response plan development, and NYDFS 72-hour and SEC 30-day notification preparation. Know exactly what to do — and what to document — before an incident occurs.

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Our Approach

Defensible Programs
Built for Scrutiny

We understand what examiners look for because we have spent years advising institutions on what regulators actually scrutinize. Our work is designed to withstand review, not merely satisfy internal stakeholders.

Regulatory Fluency

We work exclusively in the language of your examiners. Our deliverables reference the specific rule language your regulator will cite, making examination responses straightforward rather than reactive.

Right-Sized Counsel

The typical small RIA or broker-dealer does not require a $25,000-per-month managed security provider. They need a senior practitioner who understands the rules and can translate them into executable programs.

Tangible Deliverables

Every engagement produces work product you can place in front of your board, your regulator, or your E&O carrier. We do not deliver slide decks — we deliver documented programs and signed certifications.

Complimentary Resource

Financial Services
Cybersecurity Compliance
Checklist

A practical reference covering the most common examination deficiencies across NYDFS, SEC, and FINRA reviews. Used by compliance officers at RIAs, broker-dealers, and insurance companies.

  • NYDFS Part 500 amended requirements — what changed and what examiners now test for
  • SEC Rule 206(4)-9 written policy and governance requirements
  • Top 10 FINRA cybersecurity deficiencies from recent exam findings
  • MFA, access control, and privileged account management checklist
  • Incident response and regulatory notification requirements
  • Vendor and third-party risk management essentials
Request the Checklist
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