SEC cybersecurity disclosure rules
Public companies and registered investment advisers need clear governance descriptions, incident escalation processes, materiality assessment discipline, and board reporting that can survive filing scrutiny.
Financial Services
Financial services regulators have gotten smarter. Your governance program needs to keep pace.
Cyturity helps financial institutions, FinTech firms, and investment organizations define the governance, resilience, and evidence structure that holds under SEC, FINRA, NYDFS, OCC, FDIC, Federal Reserve, and DORA examination expectations.
The Problem
The examination changed. Many programs did not.
Financial services has always been heavily regulated. What has changed is the nature of the examination.
Regulators have moved from asking whether a program exists to evaluating whether it works continuously. SEC cybersecurity disclosure rules require organizations to describe cybersecurity governance in terms boards and investors can evaluate. NYDFS Part 500 amendments increased expectations around senior accountability, incident reporting, business continuity, disaster recovery, and third party oversight. OCC and Federal Reserve examiners ask operational resilience questions that go beyond policy documentation. FINRA continues to focus on cybersecurity controls, vendor oversight, and current evidence.
Many governance programs have not kept pace.
Programs built around periodic attestation are now being asked to prove continuous control operation. Evidence that was sufficient in the last review may not satisfy the next one. Vendor programs built around annual questionnaires are being evaluated against how relationships are governed during disruption.
Governance should support digital change, vendor decisions, customer trust, regulatory readiness, and executive risk decisions without slowing critical financial services work.
The Regulatory Landscape
Five regulators, one governance program
NYDFS Part 500
Covered entities need continuous compliance evidence, senior governance accountability, incident reporting readiness, business continuity and disaster recovery testing, and third party service provider oversight.
OCC and Federal Reserve operational resilience
Banking regulators expect critical operations identification, dependency mapping, impact tolerance thinking, and recovery capability validation.
FINRA cybersecurity and third party risk
FINRA examination priorities continue to include cybersecurity controls, vendor oversight, and the evidence firms maintain around both.
DORA for EU operations
Financial entities operating in the European Union face ICT risk management, incident reporting, resilience testing, and third party ICT provider oversight requirements that many legacy programs do not fully address.
The Cyturity Approach
Governance that operates between examinations
Continuous governance that replaces periodic attestation
We define ownership, evidence management, and a review checkpoint that surfaces stale evidence or unresolved control gaps before the next examination, not during it.
Regulatory mapping that reduces redundant work
We map overlapping requirements across SEC, NYDFS, OCC, FINRA, DORA, SOC 2, NIST CSF, and related expectations into a unified governance structure.
Operational resilience that supports examiner expectations
We define critical operations mapping, dependency visibility, impact tolerance support, and recovery validation structures that reflect current operations.
Third party risk management that goes beyond questionnaires
We define vendor governance around operational dependencies, recovery timeline alignment, contractual resilience expectations, ongoing evidence, and escalation protocols.
Where to Start
Connect the industry problem to the next useful step
Advisory Diagnostic
Assess ownership, evidence, decision flow, and operating gaps before choosing a remediation path.
Explore Advisory Diagnostic
Cyber Insurance Readiness
Align control evidence, ownership, and recovery governance to underwriting and claim scrutiny.
Explore Insurance Readiness
Executive Risk Decisions
Give leaders the context and decision path needed to move risk work forward.
Explore Risk DecisionsThe Outcome
Governance regulators can trace and leaders can operate
Financial services regulators are not going to ask easier questions next year.
The organizations that navigate examination pressure with fewer findings are the ones that structured governance programs for current expectations, not earlier ones.
When an examiner asks whether the program works, the answer should come from a named control owner, current evidence, and a decision path that was already clear before the examination started.
Start With One Meeting
See what to fix first.
Clarify the governance, evidence, and decision gaps most likely to surface in an examination, board review, or policy renewal.
See What To Fix First