What Are the Minimum Cybersecurity Controls FINRA Expects Financial Firms to Have?

FINRA expects financial firms, regardless of size, to maintain a baseline set of cybersecurity controls designed to protect client information, manage operational risk, and demonstrate accountability. For firms with 20–50 employees, regulators consistently look beyond basic antivirus software and firewalls and focus on whether cybersecurity is governed, documented, tested, and overseen by leadership. Firms that fail to implement these minimum controls often face audit findings, remediation requirements, or increased regulatory scrutiny. When implemented correctly, these controls form the foundation of long-term compliance and operational resilience.

Governance & Security Ownership

Regulatory Expectation

FINRA expects firms to demonstrate clear ownership of cybersecurity, including accountability for decisions and oversight.

Minimum Controls Include:

Why this matters: If cybersecurity ownership is unclear, regulators view the program as fragmented, even when technical tools are in place.

Cybersecurity Risk Assessments & Documentation

Regulatory Expectation

Cybersecurity risk management must be ongoing, not a one-time activity.

Minimum Controls Include:

Key principle: FINRA looks for proof that risks are identified, evaluated, and addressed over time — not just acknowledged once.

Identity, Access & Authentication Controls

Regulatory Expectation

Access to systems and sensitive data must be restricted, justified, and monitored.

Minimum Controls Include:

Common issue: Even a single system without proper access controls can result in audit findings.

Incident Response Planning & Testing

Regulatory Expectation

Firms must be prepared to detect, respond to, and recover from cybersecurity incidents.

Minimum Controls Include:

Important note: Incident response plans that are not tested are often treated as ineffective during regulatory reviews.

Monitoring, Detection & Endpoint Protection

Regulatory Expectation

Cybersecurity programs should emphasize early detection, not just recovery after an incident.

Minimum Controls Include:

Outcome: Firms with proactive monitoring demonstrate stronger cybersecurity maturity during exams.

Vendor & Third-Party Risk Management

Regulatory Expectation

Firms remain responsible for the security of third parties that access sensitive data.

Minimum Controls Include:

Key insight: Outsourcing services does not outsource regulatory responsibility.

Security Awareness & Employee Training

Regulatory Expectation

Employees must understand their role in protecting firm and client data.

Minimum Controls Include:

Why it matters: Human error remains one of the most common causes of cybersecurity incidents.

Business Continuity & Data Protection

Regulatory Expectation

Firms must be able to continue operations during and after disruptive events.

Minimum Controls Include:

Regulatory focus: FINRA looks for evidence that recovery plans work — not just that they exist.

Example: Applying a Minimum Control Framework

Netready helped a financial services firm in Southern California with approximately 31 employees implement a standardized cybersecurity control framework aligned with regulatory expectations. After completing a risk assessment, enforcing multi-factor authentication, testing incident response procedures, and documenting vendor oversight, the firm demonstrated measurable risk reduction and successfully navigated a regulatory review without cybersecurity findings.

Final Takeaway

FINRA cybersecurity expectations are principle-based and consistent. While technologies evolve, regulators continue to focus on governance, accountability, risk management, and preparedness. Financial firms that implement these minimum cybersecurity controls create a strong foundation for compliance, resilience, and long-term operational stability.