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Cybersecurity and Resiliency Observations

SECURITIES AND EXCHANGE COMMISSIONC ybersecurity and Resiliency ObservationsOFFICE OF COMPLIANCE INSPECTIONS AND EXAMINATIONSDISCLAIMER: This statement represents the views of the staff of the Office of Compliance Inspections and Examinations (OCIE). It is not a rule, regulation, or statement of the Securities and Exchange Commission. The Commission has neither approved nor disapproved its content. This statement, like all staff guidance, has no legal force or effect: it does not alter or amend applicable law, and it creates no new or additional obligations for any and Risk Management ..2 Access Rights and Controls.

• Policies and Procedures. Adopting and implementing comprehensive written policies and procedures addressing the areas discussed below and identified risks. • Testing and Monitoring. Establishing comprehensive testing and monitoring to validate the effectiveness of cybersecurity policies and procedures on a regular and frequent basis.

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