Cybersecurity/Financial Cybersecurity
Financial Cybersecurity
Protect the Institution. Protect the Client. Demonstrate the Controls.
Financial organizations operate in an environment where sensitive information, financial assets, technology, third-party dependencies, cyber-enabled fraud and regulatory oversight intersect. Cybersecurity requires more than documented policies or periodic assessments. Gregg Global helps financial organizations understand their exposure, assess vulnerabilities and controls, prioritize remediation, verify security posture and build greater resilience as threats, technology and requirements evolve.
Common Threats. Institution-Specific Exposure.
A broker-dealer is not an investment adviser. A bank is not a credit union.
Different organizations may hold different information, conduct different transactions, rely upon different technologies and third parties, and operate under different regulatory requirements. Effective financial cybersecurity begins with understanding the institution rather than applying a generic security model.
The Financial Cybersecurity Environment
Interconnected systems. Evolving requirements. Continuous exposure.
Cybersecurity posture results from the interaction of these elements — not a single security technology protecting the entire institution.
Financial Institution
People · Assets · Clients · Trust · Resilience
People & Identity
Employees, advisors, contractors, customers
Technology & Access
Endpoints, mobile/BYOD, networks, cloud, SaaS, APIs
Data & Transactions
Customer info, credentials, financial records, payments
Extended Ecosystem
Banks, fintech platforms, cloud/MSSP, payment & data providers
A Complex and Evolving Regulatory Environment
Select an institution type.
Registration, charter, business activities, jurisdiction, information handled, customers served and regulatory authorities all influence what obligations may apply. Gregg Global evaluates the cybersecurity environment in the context of the institution's specific profile rather than applying one generic framework.
Broker-Dealer
Broker-dealers operate under overlapping SEC and FINRA cybersecurity, supervisory, privacy, business-continuity, recordkeeping and cyber-enabled-fraud expectations.
Cybersecurity
Written safeguards, supervisory controls, identity and access management, vulnerability management, resilience.
Incident Response
Written procedures, detection, containment, recovery, escalation, and customer notification where applicable.
Privacy & Data
Protection of customer records, nonpublic information, and identity-theft controls where applicable.
Third-Party Risk
Initial and ongoing due diligence, breach monitoring, contingency planning, GenAI review.
Evidence
Policies, supervisory records, incident documentation, testing results supporting exam readiness.
Investment Adviser
Applicability differs materially between SEC-registered and state-registered advisers, but governance, safeguards, incident readiness and demonstrable controls remain central.
Cybersecurity
Governance, access controls, DLP, risk assessment, vulnerability management, control testing.
Incident Response
Detection, containment, recovery, escalation and notification duties where applicable.
Privacy & Data
Safeguarding nonpublic personal information under applicable federal and state regimes.
Third-Party Risk
Service-provider oversight, security due diligence, contractual safeguards, ongoing monitoring.
Evidence
Risk assessments, control evidence, vendor reviews, examination-ready documentation.
Bank
Banks operate within a safety-and-soundness framework integrating cybersecurity, operational resilience, customer-information protection, and third-party risk.
Cybersecurity
Enterprise information-security program, control implementation, resilience, monitoring.
Incident Response
A qualifying incident can require notice to the primary federal regulator as soon as possible, no later than 36 hours after determination.
Privacy & Data
GLBA and agency-specific safeguards for customer information.
Third-Party Risk
Full lifecycle governance: due diligence, contracting, ongoing monitoring, concentration risk.
Evidence
Risk assessments, control testing, board reporting, resilience plans, examination support.
Credit Union
Credit-union cybersecurity centers on member-data protection, governance, payments, fraud prevention, third-party oversight and resilience.
Cybersecurity
Risk-based security program, governance, access management, payment security, resilience.
Incident Response
Federally insured credit unions must notify NCUA as soon as possible, no later than 72 hours after reasonable belief a reportable incident occurred.
Privacy & Data
Protection of member information under GLBA-related safeguards plus applicable state requirements.
Third-Party Risk
Vendor due diligence, outsourced-function oversight, payment-provider risk, monitoring.
Evidence
Board oversight, risk assessments, incident records, resilience testing, examination documentation.
Insurer / Producer
Insurance cybersecurity is primarily state-driven, so applicability can vary significantly by license, jurisdiction, entity size, and whether an additional regime applies.
Cybersecurity
Risk-based information-security program, access controls, governance, testing.
Incident Response
Under NAIC Model #668 where adopted, notice to the commissioner as promptly as possible, no later than 72 hours after determining a qualifying event occurred.
Privacy & Data
Protection of nonpublic consumer and business information under state regimes.
Third-Party Risk
Due diligence, service-provider expectations, contractual safeguards, breach escalation.
Evidence
Security-program records, event documentation, regulatory filings, remediation records.
Fintech
There is no single fintech cybersecurity regime. The regulatory environment follows the activities performed, licenses held, data handled and bank-partner relationships.
Cybersecurity
Written security program where required, risk assessment, cloud and application security.
Incident Response
Response and notification duties can arise from FTC, state licensing, NYDFS, securities rules, and bank-partner contracts.
Privacy & Data
GLBA-related safeguards alongside state privacy and sector-specific requirements.
Third-Party Risk
Fintechs are often both regulated entities and critical vendors — expect due diligence in both directions.
Evidence
Control evidence, audit artifacts, vendor and subprocessor inventories, regulatory-reporting support.
Regulatory applicability varies based on registration status, activities, jurisdiction, information handled, and other circumstances. This module is for general orientation only and does not provide legal advice or determine whether a specific law or regulation applies to a particular organization. Sources: FINRA 2026 Annual Regulatory Oversight Report; SEC Regulation S-P; FDIC/federal banking agencies incident notification rule; NCUA cyber incident notification requirements; NAIC Model Bulletin #668; NYDFS 23 NYCRR Part 500; FTC Safeguards Rule.
Policy Is Not Proof
Can you demonstrate your security posture?
A written policy does not establish that the underlying security control has been implemented, operates effectively, or continues to function as the environment changes.
Requirement
What must we address?
Policy
What have we committed to do?
Control
What protects the organization?
Enforcement
Is the control actually operating?
Verification
Can we determine that it works?
Evidence
Can we demonstrate it?
The Risk Environment Is Moving Faster Than the Assessment Cycle
A point-in-time assessment is a moment, not a guarantee.
Vulnerabilities emerge. Technology changes. Users and access change. Vendors are introduced. AI adoption expands. Threat actors adjust their methods. Regulatory expectations continue to evolve.
Establish → Remediate → Verify → Monitor
Trust Must Be Continuously Earned
Access should be considered in context.
Who?
Is the identity known and appropriately authenticated?
What Device?
Is the device authorized and appropriately secured?
From Where?
Is the location and access method consistent with policy?
To What, With What Privileges?
Is the access still appropriate?
Your Cybersecurity Environment Includes the Companies You Depend On
Third-party risk.
The institution may outsource the function. It does not necessarily outsource the risk or regulatory responsibility.
Due Diligence → Assess → Require → Remediate → Monitor → Respond
Cybersecurity and Fraud Are Converging
The attack may begin with technology and end with a transaction.
AI Changes Both Attack and Defense
Innovation should expand capability without unnecessarily expanding exposure.
AI is creating new capabilities for financial organizations while changing the threat environment — AI-enabled social engineering, deepfakes, shadow AI, sensitive-data exposure and agent permissions all matter here.
From Exposure to Resilience
The same lifecycle, applied to a regulated institution.
Assess
Risk, vulnerabilities, information, identity/access, technology, third parties.
Harden
Prioritize and remediate weaknesses; verify resulting posture where appropriate.
Monitor
Maintain visibility into vulnerabilities, access, third parties, technology changes.
Prepare
Incident-response plans, roles, escalation, tabletop exercises.
Respond
Contain, preserve, investigate, assess, remediate, document.
Recover & Improve
Restore, verify remediation, document lessons, improve controls.
Understand the Risk Before Deciding the Solution
Establish your cybersecurity baseline.
For many financial institutions, a comprehensive Cybersecurity Risk Assessment is the most appropriate place to begin — evaluating more than technical vulnerabilities. Technical vulnerability scanning and penetration testing can be incorporated as appropriate to scope.
A Baseline Is the Beginning, Not the End
Ongoing cybersecurity management.
Security Posture Can Affect More Than Security
Cyber insurance.
Cybersecurity posture can become relevant to cyber-insurance underwriting, representations, coverage conditions and incident claims. Gregg Global can help assess and document technical security posture. Gregg Global does not provide insurance advice, coverage opinions, or guarantees of coverage or claim payment.
Financial Cybersecurity Capabilities
Cybersecurity Risk & Vulnerability AssessmentsRisk assessments through remediation verification
Financial Regulatory CybersecurityFramework alignment and evidence
Identity, Access & Zero TrustContinuously verified access
Vendor & Third-Party RiskThe full lifecycle
AI Risk, Governance & Secure AIWhere AI touches financial data
Cyber-Enabled Fraud RiskIdentity, payments, impersonation
Incident PreparednessRehearsed before you need it
Incident Response & Digital ForensicsContain, investigate, document
Cloud, Endpoint & Network SecurityThe technical control layer
Cybersecurity Leadership & vCISOProgram governance and reporting
Why Gregg Global
Multidisciplinary by Design
Cybersecurity, technology, investigations, forensics, risk, AI and advisory brought together as the engagement requires.
Financial-Sector Expertise
Access to experienced professionals and specialist partners with direct experience supporting regulated financial organizations.
Independent & Risk Based
We begin with the institution's environment and obligations rather than a predetermined technology.
Technology Driven
Emerging technologies evaluated on whether they improve security, governance, and risk reduction.
Verified & Documented
Corrective actions and security posture verified and documented for governance, exams and insurance.
Agile & Scalable
Engagements from a focused requirement to comprehensive, ongoing cybersecurity programs.
Can You Demonstrate Your Security Posture?
A cybersecurity program should answer more than "do we have a policy." What are we protecting? Where are we exposed? What controls are operating? Can we verify and demonstrate it? We can start there.
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Discuss Your Financial Cyber Risk
Gregg Global provides cybersecurity, technology, investigative, risk and advisory services. Gregg Global does not provide legal advice, legal representation, regulatory opinions or insurance coverage advice. Regulatory requirements vary by institution, registration, activity, jurisdiction and circumstances. Organizations should consult qualified legal and compliance professionals regarding requirements applicable to their specific operations.