Citation Edit

Securities and Exchange Commission, Division of Investment Management, Cybersecurity Guidance ("Guidance Update"), IM Guidance Update No. 2015-02 (Apr. 2015) (full-text).

Overview Edit

The SEC's Division of Investment Management guidance states that an investment fund that cannot repay shareholders because of a cyberattack risks violating federal securities laws. The guidance recommends that advisors and funds conduct periodic assessments, have a cybersecurity strategy, and have written policies and procedures to mitigate cyberattacks.

The Guidance Update sets forth a three-step approach for registered advisers and investment companies:

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