GLBA, SEC 17a-4 & FINRA cybersecurity testing.
Penetration testing and phishing simulation for banks, broker-dealers, and investment advisers navigating the Safeguards Rule, SEC recordkeeping requirements, and FINRA program reviews.
What these frameworks actually require.
GLBA / FTC Safeguards Rule (16 CFR Part 314)
The amended Safeguards Rule requires a written information security program with access controls reviewed at regular intervals and key events — onboarding, offboarding, role changes — plus technical controls like MFA and encryption. On testing specifically: either continuous monitoring, or annual penetration testing paired with vulnerability assessments at least every six months. (Institutions holding data on fewer than 5,000 consumers are exempt from the written risk assessment, annual pentest, written incident response plan, and annual board report requirements.)
SEC Rule 17a-4
Broker-dealer electronic recordkeeping historically required WORM (write-once, read-many) storage. Since the 2022 amendments, firms can instead use an audit-trail alternative — a system that preserves a complete, time-stamped record of every modification or deletion, including who made it and when, for the full retention period.
FINRA cybersecurity program reviews
FINRA examiners directly ask what training a firm conducts on cybersecurity, including phishing — and expect firms to run regular phishing simulations, adjust training based on results, and retain reports and trend metrics as evidence. Documented testing history is what examiners are actually looking for, not just a policy on paper.
How this maps to what we do.
GLBA / Safeguards Rule
Maker-checker dual approval on every campaign launch, plus host-isolated, envelope-encrypted credential storage, support the Safeguards Rule's access-control and information-security-program documentation requirements.
SEC Rule 17a-4
Our audit log is insert-only at the application layer — no code path updates or deletes a written record — which supports the spirit of Rule 17a-4's non-rewritable recordkeeping expectation. Pair with your own WORM-compliant storage backend for full retention-rule coverage; we don't claim to replace that layer.
FINRA Program Review
A timestamped record of every campaign, approval, and result gives your cybersecurity program exactly the training-and-testing evidence FINRA program reviews ask to see.
Program review or Safeguards Rule audit coming up?
Tell us your regulator and your timeline — we'll scope testing that produces the evidence they'll ask for.