The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu The leading online blog in the fields of corporate governance and financial regulation. Mon, 18 May 2026 13:57:32 +0000 en-US hourly 1 https://wordpress.org/?v=6.5.8 https://corpgov.law.harvard.edu/wp-content/uploads/2024/02/cropped-photography-4-e1706898544564-1-32x32.png CFTC’s Proposed Rules on Cybersecurity – The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu 32 32 CFTC’s Proposed Rules on Cybersecurity https://corpgov.law.harvard.edu/2016/01/02/cftcs-proposed-rules-on-cybersecurity/?utm_source=rss&utm_medium=rss&utm_campaign=cftcs-proposed-rules-on-cybersecurity https://corpgov.law.harvard.edu/2016/01/02/cftcs-proposed-rules-on-cybersecurity/#comments Sat, 02 Jan 2016 14:51:04 +0000 https://corpgov.law.harvard.edu/?p=72241?d=20160102095207EST Posted by Dan Ryan, PricewaterhouseCoopers LLP, on Saturday, January 2, 2016
Editor's Note:

Dan Ryan is Leader of the Financial Services Advisory Practice at PricewaterhouseCoopers LLP. This post is based on a PwC publication by Mr. Ryan, Sean Joyce, Joseph Nocera, Jeff Lavine, Didier Lavion, and Armen Meyer.

Last week, the Commodity Futures Trading Commission (CFTC) proposed cybersecurity regulations for electronic trading platforms, clearing organizations, and data repositories. Most importantly, the proposal calls for five types of systems testing, the most impactful of which is the requirement that organizations test key controls (e.g., access to sensitive data or procedures that control changes to critical systems).

Guidance from other regulators thus far has come in the form of examination guidelines or self-assessment tools rather than regulations. [1] The CFTC’s proposal would be the first cybersecurity regulation, and some other regulators are likely to follow suit. [2]

(more…)

]]> https://corpgov.law.harvard.edu/2016/01/02/cftcs-proposed-rules-on-cybersecurity/feed/ 2