As the coronavirus pandemic continues, fund managers are facing fallout to various parts of their businesses. In addition to ensuring the ongoing safety and productivity of their employees, managers must address increased cybersecurity risks from a distributed workforce, while also limiting disruptions to their marketing and investment activities. To aid with mitigating those risks, the Hedge Fund Law Report interviewed several legal professionals on how fund managers can smoothly navigate the coronavirus pandemic. This second article in a three-part series recommends disclosures to provide while marketing during this period, features to review in key person provisions and cyber risks to mitigate. The first article
detailed the SEC’s relief for Form ADV and Form PF filings, as well as guidance for communicating with investors and managing liquidity risks introduced by the coronavirus. The third article
will prescribe best practices for fund managers to ensure business continuity, mitigate vendor risks and otherwise avoid operational disruptions. For more on cybersecurity risks, see “How Fund Managers Can Establish Effective Incident Response Plans
” (Jul. 18, 2019); and “Steps Hedge Fund Managers Should Take to Defend Against the Rising Threat of Ransomware in the Wake of WannaCry
” (Jun. 15, 2017).