Appolo Compliance is a firm specialized in designing and implementing comprehensive information security programs.

We help start-up and existing investment advisers increase investor confidence in the resiliency of their information security programs against cyber threats and attacks.

    frequently asked questions (FAQ)

    Will the U.S. Securities Exchange Commission (SEC) adopt new cybersecurity regulations?


    On February 9, 2022 the SEC proposed new cybersecurity to address cybersecurity risk management under the Investment Adviser Act of 1940 and Investment Company Act of 1940.

    The proposed rule would apply to investment advisers that a registered with the SEC, registered investment companies and closed end funds that decide to be treated as business development companies.

    What are the privacy and cybersecurity rules that apply to investment advisers?


    As fiduciaries, investment advisers are required to always act in the best interest of their clients. Thus, they should take steps to minimize cybersecurity risks that may lead to the loss of access to accounts or investments, potentially resulting in the loss or theft data or assets.
    Moreover, 17 CFR 275.206(4)-7 (“Advisers Act compliance rule”) requires advisers to consider their fiduciary and regulatory obligations and formalize policies and procedures reasonably designed to address them.

    Other Commission rules require advisers and funds to consider privacy and cybersecurity. For example, advisers subject to 17 CFR 248.1 through 248.31 (“Regulation S-P”) are required to, among other things, adopt written policies and procedures that address administrative, technical, and physical safeguards for the protection of customer records and information. These written policies and procedures must be reasonably designed to protect the security and confidentiality of customer records and information.

    Under the Gramm-Leach-Bliley Act, a financial institution must provide its customers with a notice of its privacy policies and practices, and must not disclose nonpublic personal information about a consumer to nonaffiliated third parties unless the institution provides certain information to the consumer and the consumer has not elected to opt out of the disclosure.

    What are the benefits of a comprehensive information security program?


    A comprehensive information security program is a growth accelerator because it protects brand reputation, builds trust and increases investor confidence in an investment adviser’s ability to protect their information against cyber threats and attacks.

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    Appolo Compliance | New York, New York | | 332-910-8302