Based on member feedback, we are in the process of redesigning our Resource Library, as well as working on an improved search feature. In the meantime, if you need assistance finding a resource or would like to discuss an issue with a member of the legal team, please contact us at IAALegalTeam@investmentadviser.org.
Results of the IAA’s 10-question member survey on the costs and burdens associated with the SEC’s cybersecurity proposal, which we believe the SEC severely underestimates. These results can help members benchmark their cybersecurity-related costs.
We recommend changes to proposed cybersecurity rules that would require investment advisers to adopt and implement written cybersecurity policies and procedures with specified elements, report significant adviser cybersecurity incidents to the Commission, disclose significant adviser cybersecurity risks and incidents to clients, and maintain related books and records.
The IAA commented on the SEC’s re-proposal of amendments to Form 13F that (i) additional identifying information in Form 13F is not needed, (ii) the SEC could provide managers with flexibility to choose an alternative identifier to a CUSIP and should study holistically issues raised by requiring the use of licensed security identifiers, and (iii) the SEC should not make technical amendments to the well-established rounding conventions or how a security’s value is reported.
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