id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
cblr-1709	Auman, Jason	Hacking Our Securities Disclosure System: The Need For Federal Broker-Dealer Disclosure Requirements Vis-À-Vis Cyber Incidents	2019	42	.pdf	application/pdf	12812	580	40	[Vol. 2018 income and net worth.1 However, according to a 2015 Securities and Exchange Commission (“SEC”) report, eighty- eight percent of broker-dealers have been the victims of cyberattacks, a significant number of which involved losses of over $5000.2 Moreover, cyberattacks in the financial sector have grown more frequent and sophisticated due to technological advances, adjustments in firm business models, and changes in how customers use technology, each of which cause new vulnerabilities in firm information systems.3 Other than a handful of famous data breaches, such as those involving Fidelity in 20144 and TD Ameritrade in 2007,5 a lack of public disclosure requirements means that little is known about the extent of broker-dealer cyber safety.6 Under current SEC regulations, broker-dealers must take preventative actions like establishing safeguards against cyber breaches and maintaining security programs that can identify red flags.7 These include adopting policies and procedures to protect customer information and to detect, 1 What to Expect When You Open a Brokerage Account, FIN. [Vol. 2018 interpretation of the Gramm-Leach-Bliley Act requirement that banks maintain programs ensuring the security of customer information and protecting customer information against unauthorized access.47 More importantly, the guidance prescribes a risk-based incident response program, including timely notification of customers affected by a breach.48 The regulatory agencies clarify that the circumstances requiring notification are instances in which the bank has reason to believe that “misuse of its information about a customer has occurred or is reasonably possible.	cache/cblr-1709.pdf	txt/cblr-1709.txt