Cyber Security Threats and Your Private Information

Throughout 2014, news headlines contained stories about the breach, and theft, of Non-Public Information; or NPI. From retailers to financial institutions to movie producers, it is evident that our private information is under attack more than ever.

In response to this new wave of cyber security threats, the SEC has announced a Cybersecurity Initiative. This initiative, announced in an OCIE Risk Alert on April 15th, 2014, emphasizes the importance of strong cyber security among the Investment Adviser (IA) community and announced targeted examinations of IAs to ensure their compliance with SEC Best Practices. 

Among these practices is a five step procedure which organizes basic cyber security functions:

1)  Identify any cyber security risks;

2)  Protect NPI;

3)  Detect any threats to the advisers system;

4)  Respond to any breach of private client information; and

5)  Recover any NPI lost and update policies to reflect new threats.

BeManaged has adopted these new policy guidelines as a part of our Compliance Policies and Procedures in order to provide further protection for our clients and their private information.

While BeManaged cannot ensure complete protection from every threat, we have taken steps beyond SEC requirements in an attempt to provide the most secure system for our clients NPI.

BeManaged does not share ANY client NPI with third parties unless permission is first granted by the client or, dissemination of NPI is required by law. Further, no third party has access to our clients’ NPI. Only BeManaged employees, who are subject to our company Code of Ethics, can access client NPI for use in account management.

Additionally, BeManaged has investigated all platforms on which client NPI is stored to ensure those electronic sites are taking steps to protect our clients’ privacy interests. BeManaged also contracted with a trusted third party to provide technology support; including monitoring of our computer systems to prevent attacks from malicious software.

It is a difficult time for individual privacy and BeManaged understands the importance of protecting your account from cyber attacks.


Jonathon Whaley is a graduate of the Ave Maria School of Law, is a licensed attorney in the State of Michigan, and has been awarded the Investment Adviser Certified Compliance Professional designation. He serves as the Chief Compliance Officer for BeManaged. Please feel free to call him at 616.871.0751, or email him at with any questions about our privacy policies and procedures.