October is Cybersecurity Awareness Month, making it the perfect time to assess your firm’s cybersecurity posture and ensure your controls remain effective. Threats targeting private fund managers continue to evolve and regulators are closely monitoring how firms protect client data and maintain operational resiliency.

Here’s a quick self-checklist to guide your review:

1. Cybersecurity Policies & Procedures

Have your written policies been updated this year to reflect new threats, regulatory guidance or technology changes? They should address access controls, data encryption, remote work oversight, vendor management and incident response planning.rowth,” the letter directly countered a July statement from Republican officials discouraging net-zero commitments and ESG-aligned frameworks.

2. Annual Cyber Risk Assessment

Has your firm conducted and documented a formal cyber risk assessment in the past 12 months? This process helps identify vulnerabilities across systems, staff and third-party providers while demonstrating regulatory due diligence.

3. Employee Cyber Awareness Training

Are all staff members completing ongoing cybersecurity training? Reinforcing phishing awareness, password hygiene and data handling practices reduces the human risk factor.

4. Vendor Management Oversight

Do you maintain an updated inventory of vendors and assess their cybersecurity posture? Regulators expect firms to evaluate vendor risk, especially for custodians, CRMs and portfolio management systems.

5. Incident Response & Business Continuity

Do you have a current incident response plan that’s been tested recently? Tabletop exercises or simulations help ensure your team can respond quickly and minimize impact.

6. Multi-Factor Authentication (MFA) and Access Controls

Is MFA enforced across all systems, including client portals, email and internal applications? Role-based access and prompt user offboarding are key safeguards against unauthorized entry.

7. Ongoing Monitoring & Testing

Are you reviewing logs, patching software and monitoring for anomalies? Continuous monitoring helps detect issues before they escalate into breaches.

Take Action This Month:

• Schedule your annual cybersecurity review
• Test your incident response plan
• Refresh employee training
• Verify vendor cybersecurity certifications

Cybersecurity isn’t just an IT issue — it’s a fiduciary responsibility. Taking proactive steps helps protect your clients, your firm’s reputation and your regulatory standing.

Contact Michael Regan, Director of Cybersecurity Compliance, at [email protected] to schedule a cybersecurity readiness review.