Mar. 29, 2022
Comments on Proposed Rules for Cybersecurity Risk Management for Investment Advisers, Registered Investment Companies and Business Development Companies I do the work for a small registered investment company, a closed-end fund, approximate size $25,000,000. I work on a part-time basis. We do not have an outside investment adviser. There are 16 shareholders. No one has access to the computer I use unless I grant access (for computer help or repairs). I have limited computer knowledge - for Word Excel, Sage accounting, email and internet searches. The whole proposal is beyond my knowledge level. If we have an outsider develop a policy, I probably will not be able to comply with it, to do the testing. If the fund employs outside services to both develop a policy and to do the testing, the cost of complying could exceed the income of the fund. That sentence probably has some hyperbole in it but the costs for this fund to comply will be out of proportion to the income that the fund earns to the detriment of the shareholders. Some relief for this small closed-end fund would be very much appreciated. Carol Singer for Keyco Bond Fund, Inc.