Cybersecurity has been and remains a focus for the SEC. But FINRA is also keenly focused on cybersecurity. In fact, on May 5, 2022, FINRA released a tool to help small firms identify key cybersecurity risks and enhance their customer information protection, cybersecurity written supervisory programs and related controls. The tool, entitled “Core Cybersecurity Threats and Effective Controls for Small Firms” (Tool), highlights the most common and recent categories of cybersecurity threats facing small firms; includes questions to assist firms with addressing those threats; provides a summary of core controls small firms should consider; and contains relevant questions for firms to answer when evaluating their current cybersecurity programs. Although the Tool was written for broker-dealers, its guidance is generally applicable to fund managers’ oversight of their cybersecurity programs. This article summarizes the Tool and provides a checklist created from the questions in the Tool that managers can use to assess the sufficiency of their cybersecurity programs. See “The SEC’s Growing Focus on Retailization, AI, Cybersecurity and Private Credit” (Jun. 4, 2026).