Small Firms Must Be Ready to Comply With Amended Regulation S‑P

The SEC’s amended Regulation S‑P requires investment advisers, broker-dealers and other covered firms to strengthen safeguards for customer information, including adopting written incident response and breach notification procedures. The changes, finalized in June 2024, took effect for large firms as of December 3, 2025, and will take effect for smaller managers on June 3, 2026. This article distills key compliance takeaways from a Seward & Kissel program on preparing for the amendments, with a focus on incident response planning and third‑party oversight. See “What to Know About the Sleeping Giant That Is the SEC’s Amended Reg S‑P” (Dec. 10, 2025).

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