Recently, the Staff of the Division of Investment Management of the Securities and Exchange Commission (the “Staff”) issued updated Guidance that highlights the importance of cybersecurity of registered investment funds and registered investment advisers. The Guidance discusses a number of measures that funds and advisers may wish to consider when addressing cybersecurity risks. In particular, the Staff identified a number of measures that funds and advisers may with to consider in addressing cybersecurity risk. It further advised that funds and advisers should identify their respective compliance obligations when assessing their ability to prevent, detect and respond to cyber attacks. Fund managers and advisers should anticipate that cybersecurity will be a focal point of the Staff’s examination program. Guidance Update.
