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Amended SEC Regulation S-P compliance deadline arrives for larger firms

Larger US broker-dealers, investment advisers and funds must now have incident response programmes and notify affected customers within 30 days.

The compliance deadline for the amended Regulation S-P arrives today for larger entities regulated by the US Securities and Exchange Commission.

Key points

  • Covered institutions must maintain a written incident response programme to detect, respond to and recover from unauthorised access to customer information.
  • Affected individuals must be notified within 30 days of becoming aware of a breach of sensitive customer information.
  • Service providers must be overseen and must notify the institution within 72 hours of a breach.
  • Smaller entities must comply from 3 June 2026.

UK firms providing technology or services to US broker-dealers, investment advisers or funds should expect new contractual notification and oversight requirements.

Source: Regulation S-P amendments, Release No. 34-100155 (SEC)

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