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FinTech doesn't always mean global mega bank. There's lots of small scale start-ups that fit into the financial services category that wouldn't/couldn't afford full time InfoSec roles.

Outsourced CISO/InfoSec is a valid and reasonable thing for some companies.

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I feel like a small scale startup needs internal infosec and audit teams even more. Unlike the incumbents, who are "too big to fail" and therefore are able to get away with blatant insecurity, a startup's in a much more vulnerable position, and any security breach is significantly riskier in terms of corporate longevity.

If I was running a financial services startup, those groups would be near the front of my list in terms of internal hiring.

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