As investment adviser firms registered with the U.S. Securities and Exchange Commission (SEC) prepare for compliance with the SEC’s amended Regulation S-P Safeguards Rule, many chief compliance officers are asking an important question:
Category Archives: Incident Response Plan
Upcoming Reg S-P Deadline for Large Investment Advisers
November 25, 2025
The first major compliance deadline under the amended Regulation S-P of the U.S. Securities and Exchange Commission (SEC) is approaching quickly. Large SEC-registered investment advisers – those with $1.5 billion or more in regulatory assets under management – must comply by December 3, 2025, while smaller SEC-registered investment advisers (those under $1.5 billion RAUM) must be compliant by June 3, 2026. Given the scope of the amendments, investment advisory firms should begin preparing now to ensure their programs, service-provider agreements, and internal procedures are ready before examination.
Regulatory Alert – SEC Amends Reg S-P
May 28, 2024
The U.S. Securities and Exchange Commission (SEC) has adopted amendments to Regulation S-P which require investment adviser firms registered with the SEC to adopt written policies and procedures for incident response programs to address unauthorized access to or use of customer information including procedures for providing timely notification to customers affected by an incident involving sensitive customer information.
In this new environment of working from home during the COVID-19 pandemic, it’s important for investment adviser firms to remember to conduct initial and ongoing due diligence of the cybersecurity policies and practices (including incident response plans) of third-party vendors which maintain confidential information of your investment advisory clients and provide services through the cloud over the Internet.
