March 15, 2023
Information security is a critically important issue for investment advisers and their clients. Our members take their information security responsibilities very seriously and want to get it right. We welcome the SEC’s thoughtful consideration of ways to reduce information security-related risks and look forward to analyzing the proposed enhancements to Regulation S-P carefully. We appreciate the SEC’s recognition that an adviser’s policies and procedures should be calibrated based on its business, size, and risks. Preliminarily, we expect to have questions around the scope of how customer information is defined in the proposal, the duplicative and potentially inconsistent obligations imposed on advisers by the proposal in relation to other similar proposed rules, and the implications of proposed timeframes.
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