ICI Releases Guidance on Electronic Recordkeeping and Communications for Funds and Advisers
The Investment Company Institute has released a 94-page guide to electronic recordkeeping and e-communications. The detailed guide, which is being made available only to ICI members, covers electronic recordkeeping generally, as well as issues related to the production of electronic records to SEC examiners, SEC enforcement attorneys, and in the context of private litigation. Topics such as privilege and over-broad document requests are addressed. The guidance also discusses how firms can establish a records management program encompassing e-mails and other electronic records.