• Cybersecurity Nuts and Bolts - Division of Investment Management Updates Guidance
  • May 4, 2015
  • Law Firm: Sutherland Asbill Brennan LLP - Washington Office
  • Every day brings another front-page story about a cybersecurity breach, or so it seems.  While the topic has been a significant focus of the President, Congress, the SEC and other regulatory agencies, there is clearly no magic bullet. In its most recent Guidance Update, the SEC’s Division of Investment Management recommends a number of useful measures that investment advisers and investment companies may consider employing to address cybsersecurity risk. The Guidance reminds advisers of their obligations under Rule 206(4)-7 under the Advisers Act, which requires the adoption and implementation of written policies and procedures and an annual review of their adequacy and the effectiveness of their implementation.