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On February 9, 2022, the Securities and Exchange Commission (the SEC) issued proposed rules 206(4)-9 under the Investment Advisers Act of 1940, as amended (Advisers Act) and 38a-2 under the Investment Company Act of 1940 (Investment Company Act) (such rules collectively referred to as the ‘cybersecurity risk management rules’), to require investment advisers registered under the Advisers Act (advisers) and registered investment companies under the Investment Company Act (funds) to adopt and implement significant new written cybersecurity policies and procedures. At a high level, the proposed rules would require annual reviews, add new disclosure requirements, and add new SEC and investor reporting requirements, among other requirements.
Continue Reading SEC Proposes New Cybersecurity Rules for Investment Advisers and Investment Companies