News & Insights

SEC Webinar: Amended Regulation S-P Compliance for Small Firms

What Happened?

The SEC has announced it will hold its final Amended Regulation S-P outreach event on January 22, 2026, at 11:00 AM ET, in anticipation of the upcoming June 3, 2026, compliance deadline for small firms. Under the regulation, small firms are those with less than $1.5 billion in assets under management. This is the third webinar in a series held by SEC staff to discuss the amendments.

During this event, SEC staff will walk through:

  • The key compliance obligations and deadlines of Amended Regulation S-P;
  • What firms should expect when interacting with an SEC exam team on this regulation;
  • Real-world insights from a sample document request list and mock examination session; and
  • An Incident Response tabletop discussion.

Attendees also have the opportunity to submit questions in advance or participate live in the Q&A portion of the event.

Those attending in person must register in advance, while online attendees are encouraged to register ahead of time but may also join without advance registration. A watch link will be made available here on the day of the event, and recordings from this and prior outreach sessions will be accessible on the SEC’s Reg S-P Compliance Outreach webpage.

What Does This Mean For Me?

Any firm without Amended Regulation S-P policies and procedures must accelerate compliance efforts to stay on track for the deadline on June 3, 2026. Larger firms began their compliance with Amended Regulation S-P on December 3, 2025, and have already revamped their compliance programs for the most challenging aspects of the amendments, such as holding vendors to the 72-hour notice requirement after discovering a breach, implementing a written Incident Response Plan, and notifying customers within 30 days of becoming aware of unauthorized access to customer information. Small firms must act now to be ready for these new requirements.

These requirements are not going away. The 2026 Examination Priorities named Regulation S-P as a focus area for examinations, and one of the few enforcement actions so far during the Atkins chairmanship was on prior Regulation S-P failures.

Our team provides full support for Amended Regulation S-P. If you need help, let us know.