The California Consumer Privacy Act

The California Consumer Privacy Act (the "CCPA"), a broad statute which imposes new data privacy obligations on certain companies that do business in California, will become effective on January 1, 2020. Fund managers and other investment advisers ("Advisers") and certain of their affiliates that are currently subject to data privacy laws pursuant to the Gramm-Leach-Bliley Act ("GLBA") or the UK General Data Protection Regulation ("GDPR") may have additional obligations to consider and prepare for as the CCPA compliance deadline approaches.

Which Advisers are Subject to the CCPA

Generally, the CCPA will apply to Advisers that:

• do business in California (even if they have no place of business in California);