How Fund Managers Can Prepare for the Latest SEC Cyber Sweeps

The SEC’s Office of Compliance Inspections and Examinations has announced two new sets of cyber sweeps. This time around, the regulator’s standards have risen, the inquiries will be more rigorous and the examiners are bringing more technical expertise. By now, the SEC expects that fund managers have invested resources, technology or human capital to align their programs with SEC expectations. To assist fund managers with responding effectively, this article reviews the current and past cyber sweeps and provides advice on how to prepare for a cyber-focused examination. See our three-part series on how fund managers should structure their cybersecurity programs: “Background and Best Practices” (Mar. 22, 2018); “CISO Hiring, Governance Structures and the Role of the CCO” (Apr. 5, 2018); and “Stakeholder Communication, Outsourcing, Co-Sourcing and Managing Third Parties” (Apr. 12, 2018).

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