Cyber Breach Response Preparedness and Factors When Outsourcing the CTO Function (Part Two of Two)

How a fund manager responds to a cyber breach can carry far more weight with the SEC than the fact that the breach occurred in the first place. The firm’s chief technology officer (CTO) plays a major role in that process, making it critical that the firm place that individual in the best position to succeed. These and other topics were addressed at Troutman Sanders’ 2019 Private Funds Forum during a panel moderated by Troutman Sanders partner Wynter L. Deagle and featuring Charles Daly, manager of compliance services at Constellation Advisers, LLC; Chris Haley, legal technology director at Troutman Sanders eMerge; John Araneo, managing director and general counsel at Align Cybersecurity; and John O’Neill, senior principal consultant at ACA Compliance Group. This second article in a two-part series outlines cyber breach response preparedness and tactics for fund managers to adopt, along with tips for ensuring the effectiveness of a firm’s CTO. The first article reviewed the evolution of the SEC’s policy toward cybersecurity; general and cyber SEC sweep examinations; difficulties from incongruent state privacy laws; and tips for developing an effective cybersecurity program. For more from Troutman Sanders partners, see our two-part series on PE investments in renewable energy projects: “Unique Trends, Advantages and Considerations” (Nov. 12, 2019); and “Maximizing Available Tax Credits Using Innovative Structures” (Nov. 19, 2019).

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