The time to comply with the SEC’s amendments to Regulation S‑P (Amendments), adopted in May 2024, has arrived. The Amendments substantially expand requirements for safeguarding customer information, with mandates around the incident response program, customer notice, service provider oversight and recordkeeping. The changes pertaining to notice and incident response program requirements will prove particularly challenging for covered institutions, including investment advisers. In this guest article, Goodwin partner Kaitlin Betancourt examined those challenges and offered practical compliance guidance.

