Practical Steps That Commodity-Focused Hedge Fund Managers Can Take to Combat Cybersecurity Threats

Cybersecurity threats against hedge fund managers grow ever more sophisticated. Accordingly, the NFA’s Interpretive Notice on cybersecurity, which became effective on March 1, 2016, calls for NFA members, including hedge fund managers registered with the NFA as commodity pool operators or commodity trading advisers, to adopt an Information Systems Security Program robust enough to guard against these increasing threats. See “PLI Panel Addresses Cybersecurity and Swaps Regulation” (Nov. 5, 2015). To assist members with those preparations, the NFA recently held a “Cybersecurity Workshop” featuring senior NFA personnel and industry experts. Among other topics, panelists discussed critical cybersecurity threats, response plans, training and other practical cybersecurity measures. This article summarizes the panelists’ discussion of these issues. For additional coverage of the NFA’s Cybersecurity Workshop, see “Hedge Fund Managers Face Imminent NFA Cybersecurity Deadline” (Feb. 25, 2016).

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