Mar 42022

Newly Proposed SEC Cybersecurity Risk Management Rules and Amendments for Registered Investment Advisers and Funds

Jay G. Baris, Nathan J. Greene, Colleen Theresa Brown, Sujit Raman and Sasha Hondagneu-Messner
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On February 9, 2022, the U.S. Securities and Exchange Commission (SEC) proposed comprehensive rules for registered advisers and funds. Among other things, these rules will require advisers and funds to implement written policies and procedures designed to address cybersecurity risks, report significant cybersecurity incidents to the SEC within 48 hours using a proposed form, and keep enumerated cybersecurity-related books and records. Initial reactions have been mixed, including a published dissent from Commissioner Hester Peirce. A public comment period is ongoing.

Read more.

This post is as of the posting date stated above. Sidley Austin LLP assumes no duty to update this post or post about any subsequent developments having a bearing on this post.

Jay G. Baris

New York

jbaris@sidley.com

Nathan J. Greene

New York

ngreene@sidley.com

Colleen Theresa Brown

Washington, D.C.

cbrown@sidley.com

Sujit Raman

Sasha Hondagneu-Messner

New York

shondagneumessner@sidley.com

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