Boulder Partner David Zetoony, Denver Counsel Elizabeth Kemery Sipes, and DC Associate Joshua James published an article in the Journal of Investment Compliance regarding data security issues that financial services firms currently face and how to overcome them. Financial services firms risk potential financial implications and increasing regulatory ramifications, such as fines, penalties and enforcement actions, for failing to implement tailored cybersecurity programs. The article provides a guide for designing policies and procedures related to cybersecurity programs, including considerations for designing a document retention policy, drafting an incident response plan, and starting or evaluating a bounty program. The article is the result of three previous client alerts written by the authors and published on the Bryan Cave website. To read one of the client alerts, click here.