On May 16, 2024, the SEC issued a release (the “Release”) adopting amendments to Regulation S-P (the “Amendments”) that require broker-dealers, registered investment companies (together, with business development companies, “registered funds”) and registered investment advisers to adopt written policies and procedures creating an incident response program to deal with unauthorized access to customer information, including procedures for notifying persons affected by the incident within 30 days. The Amendments are substantially identical to the proposals in the 2023 proposing release.
Click here to read the Ropes & Gray client alert for more details on the Amendments.