News & Insights: Regulation S-P

Amended Reg S-P Deadline for Smaller Advisers: Less Than Two Months Left

The final compliance deadline of Amended Reg S-P is finally here. For smaller entities, who manage less than $1.5B in AUM, there are less than two months until the June 3, 2026, deadline.

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Regulation S-P Speech from the Director of the SEC’s Division of Examinations

On May 19, 2025, SEC Chair Paul Atkins gave a speech during his first SEC Speaks conference as SEC Chairman. In his remarks, Atkins covered the SEC’s current priorities, most of which should come as no surprise: innovation at the SEC, cryptocurrency, FinHub, investing in private funds, and the Consolidated Audit Trail (CAT). More details on each are included below.

Regulatory Preparedness 2025: Amended Reg S-P and AML/CFT

As we approach the mid-point of 2025, two compliance deadlines stand out for compliance professionals, amended Regulation S-P and FinCEN’s Anti-money laundering/countering the financing of terrorism Rule (the “AML/CFT” Rule).

Reminder: Plan for Amended Regulation S-P in 2025 Budget Planning

As we near budget planning season for many firms, large entities in particular (including RIAs with $1.5 billion or more in AUM) should be sure to account for costs that may be associated with complying with Amended Regulation S-P.

Amendments to Regulation S-P Published to Federal Register

On June 3rd, 2024, the SEC’s adopted amendments to Regulation S-P were published to the Federal Register. The adopted amendments become effective within 60 days of publication, on August 2nd, 2024.

SEC Adopts Rule Amendments to Regulation S-P to Enhance Protection of Customer Information

The SEC adopted amendments to Regulation S-P requiring broker-dealers, investment companies, registered investment advisors, and transfer agents to implement and maintain policies and procedures regarding an incident response program that are designed to detect, respond, and recover from unwarranted access or use of client information.

Regulation S-P Overview

Regulation S-P became effective on November 13th, 2000, and requires financial institutions to provide notice to customers regarding the financial institution’s privacy policies; the condition under which they may disclose nonpublic personal information about consumers to nonaffiliated third parties; and provide an “opt out” method for consumers to prevent the financial institution from disclosing information.  

SEC Reopens Public Comment on The Cybersecurity and Risk Management Rule and Proposes Changes to Reg S-P to Enhance Protection of Customer Information

On Wednesday, March 15, the SEC held an opening meeting and announced three proposed rules touching on cybersecurity and also reopened its proposed Cybersecurity Risk Management Rule for more public commentary

OCIE Warns Advisers and Broker-Dealers of Regulation S-P Compliance Issues

Regulation S-P requires registered investment advisers, investment companies, and broker-dealers to provide notice to customers and maintain written records of policies and procedures related to information privacy.

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