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IAA letter calls on the SEC to conduct a holistic and cohesive review of the Outsourcing, Cybersecurity, Safeguarding, Regulation S-P, and the many other rule proposals affecting advisers, as well as for a reasonable and workable implementation timeline.
The IAA supports the SEC’s proposal to amend the rules governing the protection of clients’ non-public personal information (PII), subject to certain recommendations that we believe would further the SEC’s objectives while more effectively protecting investors and streamlining unnecessary operational and compliance burdens on advisers.
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.
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