On February 4, 2015, FINRA published its report on cybersecurity practices arising out of its 2014 targeted examination of firms’ cybersecurity preparedness. The Report reflects FINRA’s risk management-based approach to cybersecurity issues, identifying principles and “effective practices” for member firms to consider, as opposed to decreeing specific requirements, policies or procedures. FINRA characterizes its intent in preparing the Report as an attempt to focus firms on a “risk management-based approach to cybersecurity” that can be tailored to each firm’s particular circumstances. . .