safeguards and disposal rules – Global Investment Law Watch

United States: SEC Compliance Outreach on Regulation S-P for Large Firms

Sep 29 2025

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.

United States: Upcoming SEC Webinar for Large Firms on Regulation S-P

Sep 23 2025

By: Jessica D. Cohn and Yonathan Y. Tewelde

The US Securities and Exchange Commission (SEC) staff will be hosting a webinar on 25 September 2025 regarding the upcoming compliance requirements under the amendments to Regulation S-P. The session is specifically geared toward large firms and is anticipated to cover expectations around incident response programs, including customer notification, the Division of Examinations’ expectations and potential Risk Alerts from the SEC staff.

United States: SEC Adopts Enhanced Privacy Safeguards

May 17 2024

By: Rich Kerr, Sasha Burstein, and Brian Doyle-Wenger

On 16 May 2024, the US Securities and Exchange Commission (SEC) adopted amendments to Regulation S-P’s safeguards and disposal rules. The amendments are designed to address the expanded use of technology and corresponding risks that have emerged since the original adoption of Regulation S-P in 2000. The amendments expand the scope of information and broaden the number of customers protected under both rules. The safeguards and disposal rule will apply to “customer information”, which includes records that contain “nonpublic personal information” as defined in the existing rule. Additionally, the amended rule expands the applicability of the safeguards rule to include transfer agents, and the disposal rules to include all transfer agents including those registered with appropriate regulatory authorities other than the SEC.

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