Next month is National Preparedness Month. From climatic issues (hurricanes, fires, earthquakes, floods...) to cybercrime, managers need to be prepared.

Because cybercrime continues to be one of the hottest topics, especially for managers, we're getting a head start on your "preparedness". If you believe that you're addressing the issue, this will be a great way to confirm that you're covering all the bases.

On October 23, 2015, the CFTC's Information Systems Security Program "("ISSP"), a program which requires Member firms to adopt and enforce written policies and procedures to secure customer data and access to their electronic systems, was adopted by the NFA. On March 1, 2016, it became effective for all NFA Member firms.

The NFA's Cybersecurity Interpretive Notice requires an ISSP to cover several key areas. Written ISSPs should contain:

• A security and risk analysis;
• A description of the safeguards against identified system threats and vulnerabilities;
• The process used to evaluate the nature of a detected security event, understand its potential impact, and take appropriate measures to contain and mitigate the breach; and
• A description of the Member's ongoing education and training related to information systems security for all appropriate personnel Detailed information can be found at https://www. nfa.futures.org/news/newsNotice.asp?ArticleID=4649. Sophisticated investors have quickly come up to speed on privacy issues and are keenly focused on how managers deal with online and offline security, reinforcing or significantly reducing the manager's "trust" factor during due diligence.

Many managers, however, don't even understand the basics of what cybersecurity is, why it's a problem, what needs to be done, how to properly prepare and protect data and how to deal with an issue, if it arises.

Even worse, if they do understand, many have taken the "it'll never happen to me" attitude. Hence, a b......................

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This article was published in Opalesque's New Managers a top-down monthly analysis, news and research publication on the global emerging manager space.