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The SEC’s recent amendments to Regulation S-P have brought significant changes for Registered Investment Advisers (RIAs) regarding data breach disclosures. According to a recent InvestmentNews article entitled SEC tightens rules around data breach disclosures, these updates, effective 60 days post-publication in the Federal Register, mandate that RIAs must establish comprehensive incident response programs and notify affected individuals within 30 days of detecting a breach.

Understanding the Changes

The SEC’s amendments reflect the evolving landscape of cybersecurity threats. These rules, modernizing a 24-year-old regulation, require RIAs to have written policies and procedures for handling data breaches. This includes measures for detecting, responding to, and recovering from unauthorized access to customer information. Notably, the regulations stipulate prompt customer notifications detailing the breach and protective steps they can take.

Implications for RIAs

For RIAs, these changes necessitate a proactive approach to cybersecurity. Firms must not only implement robust security measures but also ensure they have clear, actionable plans for breach response and communication. This shift aims to enhance transparency and protect investors, fostering greater trust in the financial advisory sector.

Preparing for Compliance

To comply with the new regulations, RIAs should focus on several key areas:

  1. Policy Development: Draft and regularly update comprehensive cybersecurity policies that align with the SEC’s requirements.
  2. Incident Response Plans: Establish and test incident response plans to ensure they can swiftly and effectively manage breaches.
  3. Client Notification Procedures: Develop clear protocols for timely and informative client notifications post-breach.
  4. Employee Training: Conduct regular training sessions to keep staff informed about cybersecurity best practices and regulatory changes.
  5. Third-Party Vendor Management: Ensure that all third-party vendors comply with the same rigorous cybersecurity standards to avoid vulnerabilities.

The SEC’s tightened rules around data breach disclosures highlight the critical importance of cybersecurity in the financial sector. By taking proactive steps to comply with these regulations, RIAs can better protect their clients’ data and maintain their trust. For detailed guidance and support, RIAs can turn to experts like Visory to navigate these regulatory changes and bolster their cybersecurity frameworks.

Read these related Visory educational articles for additional insights and best practice guidance:


Have questions about how Visory can help you prepare for these regulatory changes? Use the form below to contact one of our RIA Security Consultants.

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