For many firms, the newest SEC regulations signify a compliance challenge and a fundamental shift in how they think about cybersecurity governance, incident response, and vendor management. They’re also an opportunity to take a fresh look at your existing cybersecurity frameworks and strengthen security measures that align with business objectives and regulatory expectations. Below, Chris Harper, Executive Director of Cybersecurity Governance, answers some of the most common questions about preparing for the new requirements.  

How should firms prioritize their cybersecurity and outsourcing efforts to prepare for the SEC’s new proposals? Are there specific actions we should be taking now? 

A risk-based approach makes the most sense here. The first step is assessing your cybersecurity policies, focusing on incident response and vendor risk management.  

Many firms are discovering gaps in their frameworks, particularly around the new 48-to-72-hour incident reporting requirements and third-party oversight protocols.  

If our firm experiences a cybersecurity incident, what’s the expected timeline for reporting to the SEC, and what information would we need to have ready? 

The compressed 48–72-hour window for reporting significant cybersecurity incidents presents interesting challenges. The focus should be on preparation rather than speed alone; success depends mainly on having the right elements in place beforehand: 

  • Clear incident classification guidelines 
  • Ready-to-use documentation templates 
  • Streamlined data collection processes 
  • Well-established stakeholder communication channels 

A solid incident response plan needs procedures for efficiently gathering incident details, assessing client impact, and documenting remediation steps, all while keeping the information accessible and organized.  

What are the critical elements of an effective incident response plan that would align with SEC and DORA regulations?  

With both SEC and DORA regulations in play, incident response frameworks need to evolve. Success hinges on building a comprehensive foundation that includes: 

  • Clearly defined roles and responsibilities, including designated backups for key positions.  
  • Flexible escalation procedures that adapt to different incident types, enabling teams to respond proportionately without over-committing resources to minor issues or underestimating serious threats.  
  • Real-time threat detection and robust communication protocols to dramatically shrink the window between when an incident occurs and when it’s discovered.  
  • Intelligent documentation systems that maintain detailed records and facilitate timely reporting to meet regulatory requirements. 
  • Regular testing and updates to stay effective. Regular drills and reviews ensure your system remains responsive to new threats and regulatory changes. 
See also  A Guide to DORA Compliance: What You Need to Know

How often should we be reassessing third-party vendors to remain compliant, and what’s the role of continuous monitoring? 

Third-party vendors should be reassessed at least annually to provide a baseline or more frequently based on risk. This more dynamic approach might include:  

  • Regular security check-ins 
  • Ongoing monitoring of security status 
  • Quick alerts for risk profile changes 
  • Risk-based in-depth reviews 

Continuous monitoring is critical in identifying changes in vendor risk profiles and spotting issues in real-time, ensuring that all vendors meet regulatory standards throughout the year.  

What key indicators should we be tracking to understand if our cybersecurity measures are effective? 

When evaluating security program effectiveness, certain metrics tend to provide particularly valuable insights: 

  • Response metrics measure how quickly incidents are detected, response time to identified threats, and resolution rates within service level agreements. 
  • Risk indicator metrics gauge the speed of vulnerability remediation, progress on critical security issues, and trends in vendor risk assessments. 
  • Threat management metrics track pattern analysis of blocked attacks, accuracy of threat detection, and employee security awareness levels. 

By maintaining a holistic view of these metrics over time, firms can adapt security measures proactively rather than reactively, ultimately creating a more resilient defense against cyber threats. 

Moving Forward 

Forward-thinking firms are seizing this moment to build integrated security frameworks that combine clear incident response protocols, rigorous vendor oversight, and data-driven monitoring. The 48 to 72-hour reporting window demands speed, preparation, and precision, and success hinges on having robust systems in place before incidents occur, supported by clear documentation and well-rehearsed response procedures.  

For more insight, please watch the cybersecurity fireside chat with Agio CEO Bart McDonough and Head of Cybersecurity, Chris Harper. If you’re a current Agio client, you can find additional information via Knowledge Articles in AgioNow. 

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