November 20, 2025
What happened?
The compliance deadline for larger advisers (those with $1.5B or more in AUM) is less than two weeks away (Dec. 3, 2025). While much of what the previous administration proposed has been tossed or postponed, the SEC has made it clear that Amended Reg S-P is not only here to stay, but it’s also a key focus area. In the SEC Division of Examinations’ recently published 2026 Exam Priorities, Amended Reg S-P is identified as a risk area for market participants.
What does this mean for me?
If you are not prepared to comply with Amended Reg S-P by Dec. 3, 2025, we recommend that you work swiftly to do so. The regulation requires specific policy updates, testing of the Incident Response Program, and extensive due diligence reviews of Service Providers. These items can be very time-consuming. Our team of SEC cyber experts provides full support for all aspects of Amended Regulation S-P. If you have questions or need support, let us know.
