FINRA & SEC Technology Compliance
FINRA and SEC cybersecurity compliance consulting for broker-dealers, investment advisers, and alternative investment firms navigating Rule 30, Regulation S-P, and SEC cybersecurity rules.
Bell Tower engineers cybersecurity programs aligned to FINRA Rule 30 and SEC Regulation S-P requirements for broker-dealers, investment advisers, hedge funds, and private equity firms.
What We Deliver
- SEC/FINRA Risk Assessment: Technology risk analysis documenting threats to customer data, trading systems, and sensitive firm information per Rule 30(a) and SEC cybersecurity guidance
- Customer Data Protection: Implementation of safeguards for non-public personal information under Regulation S-P and SEC cybersecurity rules
- Branch Office Controls: Supervisory systems and controls for remote offices, including WSPs and annual branch audits per Rule 31
- Phishing & Social Engineering Defense: Email security, MFA deployment, and incident response procedures addressing the #1 attack vector against financial firms
- Vendor Due Diligence: Third-party risk management for critical service providers (clearing, prime brokerage, cloud) with documented supervision per Rule 30(c)
FINRA & SEC Cybersecurity Implementation
Bell Tower’s financial services compliance consulting addresses the overlapping requirements of FINRA Rule 30 (Supervisory Systems and Controls) and SEC Regulation S-P (Privacy of Consumer Financial Information). We start with a risk assessment that satisfies both regulators: identifying customer data repositories, trading system vulnerabilities, email security gaps, and branch office control weaknesses.
We engineer technical controls that satisfy Rule 30’s core components: data encryption, access controls, intrusion detection, and incident response. For alternative investment firms, we address the specific SEC cybersecurity examination priorities: patch management, multi-factor authentication, phishing defense, and vendor management. Our approach maps each control to specific regulatory citations with documented rationale for implementation choices.
For firms already aligned to NIST CSF or ISO 27001, we provide crosswalk documentation showing how existing controls satisfy FINRA/SEC requirements—avoiding redundant work while ensuring examination readiness.
FINRA/SEC to Framework Crosswalks
FINRA Rule 30 and SEC requirements map directly to major security frameworks:
| FINRA/SEC Requirement | Rule/Regulation | NIST CSF Mapping | ISO 27001 Mapping | Control Description |
|---|---|---|---|---|
| Risk Assessment | Rule 30(a) | ID.RM, ID.RA | A.5.1, A.5.2 | Annual technology risk assessment |
| Data Protection | Reg S-P | PR.DS, PR.AC | A.9.4, A.13.2 | Safeguards for customer NPI |
| Access Controls | Rule 30(b) | PR.AC | A.9.2, A.9.4 | Authentication and authorization |
| Encryption | Rule 30(c) | PR.DS | A.10.1 | Data at rest and in transit |
| Phishing Defense | SEC Exam Priorities | PR.PT | A.9.1 | Email security and training |
| Vendor Management | Rule 30(c) | ID.SC | A.15.1 | Third-party due diligence |
| Incident Response | Rule 30(d) | RS.RP | A.16.1 | Detection and reporting procedures |
| Branch Supervision | Rule 31 | ID.GV | A.6.1 | Written supervisory procedures |
We map your current security program to regulatory requirements, identifying gaps between framework alignment and SEC examination expectations.
Risk Assessment Examples
The technology risk assessment is where most financial firms fail examinations. We engineer assessments that satisfy FINRA Rule 30(a) and SEC expectations:
Example: Trading System Vulnerability
Asset: Order management system with FIX protocol connectivity
Threat: Unauthorized trading via compromised credentials
Vulnerability: Shared service accounts, no session timeout, weak password policy
Likelihood: Medium (requires insider access or phishing)
Impact: Critical (unauthorized trades, regulatory violations, reputational damage)
Risk Level: High
Remediation: Implement dedicated user accounts, MFA for all system access, session timeouts, trade confirmation controls
Example: Email Compromise (Wire Transfer Fraud)
Asset: Email systems with wire transfer instructions
Threat: Business email compromise (BEC) leading to fraudulent transfers
Vulnerability: No email authentication (SPF/DKIM/DMARC), verbal-only verification
Likelihood: High (financial sector is primary BEC target)
Impact: High (immediate financial loss, client harm)
Risk Level: Critical
Remediation: Email authentication protocols, callback verification procedures, wire transfer limits, employee phishing training
Audit Evidence Library
FINRA examinations and SEC cybersecurity sweeps require proof of ongoing compliance. We build evidence libraries organized by rule:
| Rule/Regulation | Evidence Type | Source | Owner | Refresh Cadence |
|---|---|---|---|---|
| Rule 30(a) | Annual risk assessment, risk register | Risk management | CCO/CTO | Annual |
| Rule 30(b) | Access control policies, user reviews | IAM systems | IT Security | Quarterly |
| Reg S-P | Privacy notices, opt-out records | Legal/Compliance | CCO | Annual |
| Rule 30(c) | Vendor due diligence files, contracts | Vendor management | Procurement/Compliance | Annual |
| Rule 30(d) | Incident response logs, breach notifications | Security operations | CISO | Per event |
| Rule 31 | Written supervisory procedures, branch audit reports | Compliance | CCO | Annual |
From Automation to Examiner
Compliance automation tools help, but FINRA examiners and SEC staff require specific financial services context. We bridge the gap:
- Risk Assessment Documentation: Converting scan outputs into Rule 30(a) format (technology-specific threats, customer data impact, trading system vulnerabilities)
- Written Supervisory Procedures: Translating technical controls into WSP language that satisfies Rule 31 branch supervision requirements
- Vendor Due Diligence: Documenting third-party risk assessments per Rule 30(c) with financial services-specific concerns (clearing firm security, prime broker access controls)
- Incident Response: Integration with FINRA and SEC breach notification requirements (not just general cybersecurity incident handling)
Knowledge Transfer
FINRA/SEC compliance requires ongoing operation, not just documentation. We ensure your team understands:
- How to update the Rule 30(a) risk assessment when trading systems or vendors change
- WSP maintenance for branch office technology supervision
- Vendor due diligence requirements for new fintech integrations
- Incident escalation procedures for FINRA/SEC notification timelines
Your compliance program belongs to you. We engineer the controls, document the evidence, and ensure your team can operate it independently—prepared for FINRA examinations, SEC cybersecurity sweeps, and investor due diligence.
Preparing for a FINRA examination or SEC cybersecurity review? Contact us to discuss your current risk posture and evidence readiness.