Comment Letter

We write in support of the purpose and the direction of, while also providing specific comments and further recommendations with respect to, the abovementioned Proposed rule to require (i) current reporting about material cybersecurity incidents, as well as updates; and (ii) disclosures about risk management, strategy, and governance as related to cybersecurity, as published in 87 Federal Register 16,590, dated March 23, 2022 (the “Proposed Disclosure Rules”) by the Securities and Exchange Commission, for which comments are requested by May 9, 2022.

We write in support of the purpose and the direction of, while also providing specific comments and further recommendations with respect to, the abovementioned Proposed rulemakings (i) to require registered investment advisers and investment companies to adopt and implement written cybersecurity policies and procedures reasonably designed to address cybersecurity risks; and (ii) report significant cybersecurity incidents affecting the adviser; and other requirements, as published in 87 Federal Register 13,524, dated March 9, 2022 (the “Proposed Rules”) by the Securities and Exchange Commission, for which comments are requested by April 11, 2022.