Articles Tagged with CISA

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At the end of this month, the annual updating amendments for investment advisers’ Form ADV will be due. The following are some of the important annual compliance obligations investment advisers either registered with the Securities and Exchange Commission (the “SEC”) or with a particular state (“Investment Adviser”) and commodity pool operators (“CPOs”) or commodity trading advisors (“CTAs”) registered with the Commodity Futures Trading Commission (the “CFTC”) should be aware of.

This summary consists of the following segments: (i) List of Annual Compliance Deadlines; (ii) 2016 Enforcement Priorities In The Alternative Space; (iii) New Developments; and (iv) Continuing Compliance Areas.

See the deadlines below and in red



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Investment managers, particularly high priority cybercrime targets, such as hedge funds and quantitative strategy managers, are encouraged to consider the government-industry information sharing option and liability protection afforded by the new legislation.  For more information, please contact the Investment Fund and Investment Management group.

On Tuesday, October 27, the U.S. Senate approved legislation, strongly supported by business groups, that would facilitate information sharing between government and industry and provide liability protection to companies that participate. The Cybersecurity Information Sharing Act of 2015 (CISA) passed the Senate by a bipartisan vote of 74-21, setting the stage for a House-Senate conference committee that will work to resolve differences between CISA and similar legislation passed by the House in April and to prepare a final bill to be considered by both chambers of Congress for potential enactment into law.


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