SEC Issues IM Guidance Update on Cybersecurity

The SEC Division of Investment Management ("IM") issued an IM Guidance Update that discusses a number of measures to be considered by funds and advisers when addressing cybersecurity risk.

The measures recommended by the Guidance Update include:

• conducting periodic assessments of the information collected by the firm, as well as internal and external cybersecurity threats to the firm's information and technology systems;
• creating a strategy that is designed to prevent, detect and respond to cybersecurity threats; and
• implementing that strategy through written policies, procedures and training that provides guidance to officers and employees.

See: IM Guidance Update.