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ARTICLE · 15 FEBRUARY 2022

SEC Proposes Cybersecurity Risk Management Requirements For Investment Advisers And Registered Funds

Herbert Smith Freehills Kramer LLP
Herbert Smith Freehills Kramer LLP
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Herbert Smith Freehills Kramer LLP

Herbert Smith Freehills Kramer LLP

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On Feb. 9, 2022, the Securities and Exchange Commission (SEC or Commission) proposed a suite of new rules and amendments concerning cybersecurity risk management for registered investment advisers...

United StatesTechnology
Alan Friedman
Alan Friedman
George Silfen
George Silfen
Robin Wilcox
Robin Wilcox
Arielle Warshall Katz
Arielle Warshall Katz
Boaz I. Cohen
Boaz I. Cohen
Daniel Lennard
Daniel Lennard
Austin Manes
Austin Manes
Nicholas Tarnowski
Nicholas Tarnowski
John "Luke" Pizzato
John "Luke" Pizzato
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On Feb. 9, 2022, the Securities and Exchange Commission (SEC or Commission) proposed a suite of new rules and amendments concerning cybersecurity risk management for registered investment advisers (advisers) and registered investment companies, including business development companies (funds). Proposed under the authority of the Investment Advisers Act of 1940 (the Advisers Act) and the Investment Company Act of 1940 (the 1940 Act), the rules and amendments would require investment advisers and funds to adopt and implement extensive "cybersecurity risk management policies and procedures." In addition, the proposals would modify recordkeeping, disclosure and reporting requirements, obligating investment advisers and funds to maintain records of significant cybersecurity incidents, to disclose such incidents to their clients, and — for investment advisers only — to promptly report significant cybersecurity incidents to the SEC.

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