United States: SEC Compliance Outreach on Regulation S-P for Large Firms
By: Jessica D. Cohn and Yonathan Y. Tewelde
On 25 September 2025, staff from the US Securities and Exchange Commission’s (SEC) Divisions of Examinations, Investment Management, and Trading and Markets hosted a webinar discussing the amendments to Regulation S-P and what to expect when Regulation S-P is in scope of an exam. The amendments, among other things, require brokers, dealers, registered investment advisers, investment companies, and transfer agents (covered institutions) 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 individuals affected by an incident involving sensitive customer information with details about the incident and information designed to help affected individuals respond appropriately.
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