Description
Note: While the content of this webinar has been approved to provide IAR CE credit, this recorded version is purely educational and is not an IAR CE course. The IAR CE version of this content is available at the following link: https://ce4advisers.com/product/iar-ce-implementing-new-requirements-under-reg-s-p/
This course provides investment adviser representatives, compliance personnel, and senior executives with a comprehensive and practical understanding of the U.S. Securities and Exchange Commission’s 2024 amendments to Regulation S-P. These amendments significantly expand the obligations of SEC-registered investment advisers with respect to safeguarding customer information, responding to cybersecurity incidents, overseeing service providers, delivering privacy notices, and disposing of customer information.
The course explains many of the requirements of the rule adopted by the SEC and translates them into operational steps that advisory firms can implement immediately. Participants will learn the required elements of an incident response program, including procedures for assessing the nature and scope of a breach, containment and control measures, evaluation of sensitive customer information, and required documentation. The course also covers the new 30-day customer-notification requirement, the narrow exception to that requirement, national-security/public-safety delay provisions, and the content that must be included in customer notifications.
In addition, the course provides detailed guidance on service-provider oversight, including the new requirement that service providers notify an adviser within 72 hours of discovering unauthorized access to a customer information system, as well as the adviser’s obligations to ensure that affected individuals are notified. Participants will also review amended requirements for the disposal of customer information and the conditions under which an annual privacy notice must be delivered.
Although the amendments apply specifically to SEC-registered investment advisers, the course explains how similar expectations may arise under state fiduciary-duty standards. The content is educational and non-promotional, and it is designed to enhance participants’ ability to recognize regulatory obligations, evaluate operational risks, and strengthen the protection of customer information.
This course is intended for educational purposes only and does not constitute advice customized to any particular investment adviser.
Learning Objectives
Upon completing this course, participants will be able to:
- Describe the SEC’s 2024 amendments to Regulation S-P and identify which requirements apply to SEC-registered investment advisers.
- Explain the required components of an Incident Response Program and how to conduct a reasonable investigation following a cybersecurity incident.
- Apply the new customer-notification rules, including timing, content, exceptions, and circumstances requiring notification of all potentially affected individuals.
- Implement policies and procedures for supervising service providers, including due-diligence expectations and required vendor-notification timelines.
- Identify obligations related to the disposal of customer information and the delivery of annual privacy notices.
- Recognize how state securities regulators may incorporate Regulation S-P concepts into fiduciary-duty examinations, even without formal rule adoption.
Instructor(s)
Bryan Hill, President of RIA Compliance Consultants, Inc.
Jarrod James, Senior Vice President of RIA Compliance Consultants, Inc.
Continuing Education
IAR CE: This course has been approved by Prometric, on behalf of NASAA, as an IAR CE Course providing one hour of credit in the Ethics & Professional Responsibility category.
There are several additional requirements before you are eligible to receive credit:
- Login – You must be logged in during the live presentation under your email address. You cannot be logged in under someone else’s email address.
- View Entire Live Presentation – You are required to watch the entire live presentation the course. If you do not watch the entire live presentation, you will have to watch the recorded version in its entirety.
- Attendance Codes – As you watch the live presentation, you will receive two attendance codes, each containing three alphanumeric characters. Save these codes. You will need to enter the full six-character attendance code prior to accessing the final quiz.
- Purchase CE Course
- If the course is approved by NASAA for IAR CE and you purchased this webinar on an a la carte basis, you will then need to request a course discount code from RCC to utilize at https://www.CE4Advisers.com .
- If you are attending this course as part of an Annual Compliance Program package of RCC, you will need to purchase the IAR CE Course at https://www.CE4Advisers.com or use a course discount code provided under your firm’s Annual Compliance Program package. Please note that note only certain ACP packages include course discount codes.
- IAR Acknowledgement – Sign the IAR CE Acknowledgement & Attestation.
- Final Quiz – You must complete each lesson and receive a score of 70% on the final quiz to receive IAR CE credit (assuming the course has been approved by NASAA). You are only allowed three attempts on the final quiz.
- Survey. You have to answer a survey on the course and instructor.
NASAA Disclaimer
NASAA does not endorse any particular provider of CE courses. The content of the course and any views expressed are our own and do not necessarily reflect the views of NASAA or any of its member jurisdictions.
Important Disclosures
Please carefully review the following disclosures and limitations of this course.
- Although the sponsor of this course, RIA Compliance Consultants, Inc. (“Sponsor”), is an affiliate of a law firm and Sponsor may have an individual on its staff that is also licensed as an attorney providing legal services in a completely separate capacity, Sponsor is not a law firm and does not provide legal services or legal advice. A consulting relationship with Sponsor does not provide the same protections as an attorney-client relationship.
- This course is offered for educational purposes only and should not be considered an engagement with the course instructor or Sponsor. This presentation should not be considered a comprehensive review or analysis of the topics discussed today. To these educational materials are not a substitute for consulting with an attorney or compliance consultant in a one-on-one context whereby all the facts of your situation can be considered in their entirety.
- Information provided during this course is provided “as is” without warranty of any kind, either express or implied, including, without limitation, warranties and merchantability, fitness for a particular purpose, or non-infringement. The course instructor and Sponsor assume no liability or responsibility for any errors or omissions in the content of the presentation.
- To the extent that this course description or the course itself includes reference to a pending enforcement action or a consent order, please understand that the course instructor and Sponsor have not not verified the accuracy of the securities regulator’s complaint, order or other statements, and the course instructor and Sponsor are not offering any opinion whether the allegations made by the securities regulator in such enforcement action are accurate.
- The course instructor and Sponsor are not be under an obligation to advise you of any regulatory developments or subsequent changes to educational material presented in this course.
- There is no guarantee or promise that concepts, opinions and/or best practices discussed in this course will be favorably received by a regulator or result in a certain outcome in adversarial proceeding.
- Communication with the course instructor is not protected from discovery by third-parties during litigation or regulatory proceedings. Please keep questions during this course in a hypothetical form.
- Reviewing the slides and/or attending this course does not create a consulting engagement with RIA Compliance Consultants, Inc.
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