Theta Lake Blog

Marc Gilman

Marc Gilman
Gilman is a technology attorney, compliance executive, and adjunct professor of compliance at Fordham Law bringing 15 years of law, financial services, and IT experience to his leadership role at Theta Lake. Gilman’s legal expertise focus on global technology-related legal and regulatory issues, such as information management, software and product development, cybersecurity, SEC and FINRA regulation, GDPR, and electronic communications platforms. Gilman is a certified information privacy professional with both the CIPP/E and CIPP/US credentials.

Recent Posts

Examining Recent Collaboration and Chat E-comms Compliance Guidance from ESMA, FCA, FINRA, SEC

Posted by Marc Gilman on Oct 19, 2021 10:20:23 AM

It’s clear that the flexibility regulators including ESMA, the FCA, FINRA, and the SEC offered financial services firms around the relatively unfettered use of modern collaboration and chat tools like Zoom, Microsoft Teams, and Webex by Cisco during the pandemic has come to an end.  No action relief issued at the outset of COVID-19 has expired, and regulatory missives in the second half of 2021 indicate a marked change of tone and expectations for firms using dynamic communication platforms.

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Topics: compliance, chat compliance, surveillance, monitoring, regulations, electronic communications

The Need to Modernize Information Barriers Compliance

Posted by Marc Gilman on Sep 1, 2021 9:15:00 AM

As enterprise communications technologies have evolved, the related challenge of managing business rules for groups permitted to use them and communicate with one another have become more complex. In financial services, business information barriers prohibit communications between specific groups to mitigate the risk of misuse of material non-public information (“MNPI”) to prevent market abuse and insider dealing. Information barriers requirements are spelled out in FINRA Rules 2241 and 2242, Section 204A of the Investment Advisers Act, in FCA’s SYSC 10.2 Rule as well as the SEC’s Exchange Act Section 15(g), which requires broker-dealers to:

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Topics: compliance, supervision, monitoring

Our Response to Regulators on AI and ML in Financial Services

Posted by Marc Gilman on Aug 11, 2021 8:30:00 AM

Last month Theta Lake submitted a response to a request for comment from several federal banking agencies including the Federal Reserve, the Consumer Financial Protection Bureau, and the Office of the Comptroller of the Currency about the use of Artificial Intelligence (AI) and Machine Learning (ML) in financial services. In our response, we described how Theta Lake uses AI in its Security and Compliance Suite, offered thoughts about how the agencies might create a framework for assessing AI risk, and outlined a few standard practices that would facilitate strong AI development in the future.

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Topics: voice compliance, regtech, surveillance, financial services

Theta Lake Perspective: SEC’s OCIE's 2021 Exam Priorities

Posted by Marc Gilman on Mar 30, 2021 9:00:00 AM

On March 3, 2021, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) announced its 2021 Exam Priorities—the first such missive in the pandemic era. The Commission’s ability to be flexible and nimble in its approach to 2020 exams and plans for this year are laudable. To bolster that effectiveness, the recently created Event and Emerging Risk Examination Team will improve and expand OCIE’s rapid response capabilities. (I wrote more about the EERT here). Based on this year’s priorities, OCIE and EERT will be very busy in 2021.

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Topics: compliance

A Single Confidential Doc Can Leave A Company Scrambling to Recover

Posted by Marc Gilman on Jan 28, 2021 11:35:20 AM

Typically, when we think about data breaches or loss, we picture scenarios where vast troves of personal data are accessed through brute force attacks or phishing attempts, resulting in thousands or millions of records being impacted. However, the release of smaller amounts of data, even a single PDF document or PowerPoint slide, can have serious and damaging ramifications for an organization.

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Topics: compliance, security, data leakage

Desjardins Case Highlights The Need for Better Oversight

Posted by Marc Gilman on Jan 6, 2021 6:27:52 AM

On December 1, 2020, Canada's Office of the Privacy Commissioner (“OPC”) issued a report on a data security incident at the Quebec-based financial services firm Desjardins.  The Desjardins incident involved an insider at the firm who accessed, collected, and leaked the personal information of over 9.7 million customers and users from Canada and elsewhere during two year period—a staggering amount of data over an extended period of time.   

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Topics: security, data leakage

AI As A Blueprint For Fintech Startups

Posted by Marc Gilman on Dec 28, 2020 1:53:41 PM

While most startup founders would prefer not to pore over laws, regulations and interpretive materials to design a perfect product, it’s an essential exercise for those developing financial services solutions. For fintechs and the other finserv-related startups (e.g., regtech, suptech, etc.) understanding the regulatory obligations of customers and prospects will be core to your mission. In some cases, the process of interpretation and analysis might be a heavy lift involving expert outside counsel, lobbying efforts, and specialized consulting services.

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Topics: compliance

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Theta Lake provides security and compliance for modern collaboration platforms using frictionless partner integrations with Cisco Webex, Microsoft Teams, RingCentral, Slack, Zoom, and more. Using patented machine learning and NLP, Theta Lake detects risks in: video, voice, chat, and document content across what is shared, shown, spoken, and typed. Those risks are surfaced in an AI-assisted, patent-pending review workspace that adds consistency, efficiency, and scale for security and compliance teams. All of this enables organizations to safely realize the full ROI of a collaboration-first workplace while reducing the cost of security and compliance.

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