In April 2014, the SEC’s Office of Compliance Inspections and Examinations (OCIE) released a risk alert indicating that the SEC will focus on cybersecurity as a major issue. After reviewing that risk alert, many registered investment advisers were still confused about what steps are required to comply with SEC guidance on the protection of their clients’ confidential information from hackers and data breaches.
The SEC clarified those obligations beginning in September 2015. Registered investment advisers are obligated to: 1) implement robust technical controls to protect clients’ sensitive/confidential information from reasonably foreseeable threats; and 2) adopt written policies and procedures that address administrative, technical and physical safeguards for the protection of that information.
A Brief History of the SEC’s Cybersecurity Initiative
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