Cockpit OverviewSEC Reg S-PNIS-2 Directive
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SEC Regulation S-P Compliance for Registered Investment Advisers

Audit-ready compliance in days, not months. Automated evidence collection, continuous control verification, and real-time governance heatmap — at a fraction of what traditional consultancies charge.

$2.5M
Per Incident Violation
85%+
Auto-Verified Controls
Days
Not Months
350+
Frameworks
RIA compliance executive

What Is SEC Regulation S-P?

SEC Regulation S-P (17 CFR Part 248) requires registered investment advisers, broker-dealers, and investment companies to adopt written policies and procedures for protecting customer records and information. Originally adopted in 2000 under the Gramm-Leach-Bliley Act, the regulation was significantly strengthened by the 2023 amendments that introduced mandatory incident response programs, individual breach notification requirements, and vendor oversight obligations.

The compliance deadline for the amended requirements is June 3, 2026. After this date, SEC examination staff will evaluate firms against the full amended requirements. Firms that cannot produce documented evidence of compliance face enforcement actions including fines of up to $2.5 million per incident.

30-day breach notification deadline

Three New Requirements Every RIA Must Meet

1

Written Incident Response Programs

Firms must develop, implement, and maintain written procedures for detecting, responding to, and recovering from unauthorized access to customer information. A designated qualified individual must oversee the program with appropriate authority and resources. CYFAX builds these policies for you and validates them automatically.

2

30-Day Individual Notification

When unauthorized access to customer information occurs or is reasonably likely to have occurred, firms must notify each affected individual within 30 days. Notifications must describe the incident, the information involved, and provide firm contact information. CYFAX detects breaches and triggers notification workflows before the clock starts.

3

72-Hour Vendor Breach Notification

Service providers that experience a breach involving customer information must notify the covered institution within 72 hours. Firms must ensure vendor contracts include these notification clauses and maintain ongoing oversight of vendor security practices. CYFAX TPRM monitors every vendor in your supply chain continuously.


What Does Not Count as Reg S-P Compliance

Many RIAs believe they are compliant because they have one or more of the following. None of these satisfy the amended Reg S-P requirements on their own.

Cyber Insurance Is Not Compliance

A cyber insurance policy — regardless of cost — does not satisfy a single Reg S-P requirement. The SEC does not ask "do you have a cyber policy?" They ask for documented incident response procedures, monitoring evidence, access controls, and vendor oversight documentation. Insurance transfers financial risk after a breach. Reg S-P requires you to prevent and detect breaches, and prove that you can.

External-Only Scanning Misses 90% of What Examiners Ask For

Services that scan your domain from the outside and produce an aggregate risk score are measuring external hygiene only. They do not test internal security controls, validate backup configurations, check endpoint protection status, or verify that your incident response plan meets regulatory standards. An external score of 84 out of 100 means nothing to an examiner requesting evidence of continuous monitoring and control validation.

Annual Consultancy Engagements Are Point-in-Time Artifacts

A virtual CISO engagement that produces policies and conducts an annual review gives you a snapshot — not continuous compliance. The amended Reg S-P requirements emphasize ongoing detection, continuous monitoring, and the ability to produce evidence on demand. A report from six months ago does not demonstrate that your controls are working today. This model typically costs $60,000 to $180,000 annually, with penetration tests billed separately at $8,000 to $15,000 each, and the cycle repeats year after year.

SEC compliance document verification

What SEC Examiners Actually Ask For

During routine and for-cause examinations, SEC staff request documentation across ten categories. Firms that cannot produce these artifacts on demand face adverse findings.

Examiner RequirementCYFAX + PREVENT CapabilityVerification
Written information security policiesAI document review validates policy fitness against Reg S-P standardsUpload
Designated compliance officer / qualified individualAI Compliance Cockpit serves as the automated compliance intelligence layerUpload
Incident response plan documentationUpload IRP for AI fitness-for-purpose review; automatic gap identificationUpload
Employee security awareness training recordsUpload training documentation for compliance mappingUpload
Access control implementation evidencePREVENT validates MFA enforcement, credential hygiene, and access policiesPREVENT Auto
Monitoring and detection capabilitiesPREVENT NDR + continuous BAS testing produces ongoing detection evidencePREVENT Auto
Business continuity and disaster recoveryPREVENT validates backup configs, encryption status, recovery readinessPREVENT Auto
Vendor oversight documentationTPRM module scores every vendor with evidence-based risk assessmentCYFAX Auto
Regular control testing recordsContinuous BAS against 60+ controls produces timestamped evidencePREVENT Auto
Dark web and credential monitoring500B+ threat objects, 20,000+ criminal sources, named account identificationCYFAX Auto
CYFAX Compliance Cockpit governance heatmap dashboard

Two Paths to Compliance

CYFAX auto-verifies approximately 40–50% of controls through external reconnaissance alone. Here is how firms close the remaining gap to reach 85%+ verification.

Option A: Upload Evidence

No Agents. No Installs. Zero Network Access.

Upload existing security artifacts into the Compliance Cockpit. The AI engine reviews each document for fitness-for-purpose against Reg S-P requirements and updates the governance heatmap automatically.

Accepted formats: PDF, DOC, DOCX, XLS, XLSX, PNG, JPG — up to 10 files per attestation.

CYFAX attestation upload interface

Documents to upload: EDR/antivirus reports, firewall configurations, backup and encryption documentation, written policies, training records, incident response plans.

Timeline: Hours to Days

Both paths achieve 85%+ compliance verification. Start with Option A (zero friction), convert to Option B when you see how much time manual evidence costs.

CYFAX cybersecurity compliance shield

What Reg S-P Compliance Actually Costs

The traditional approach to Reg S-P compliance requires assembling 5–7 point solutions and consultants at significant annual cost. CYFAX consolidates every requirement into a single platform at a fraction of the price.

Point Solutions + Consultants

$70,000 – $110,000+/yr
  • Managed IT / vCISO: $60K–$180K/yr
  • Penetration testing: $8K–$15K per engagement
  • Vulnerability scanning: separate vendor
  • Dark web monitoring: aggregate stats only
  • Vendor risk assessment: manual questionnaires
  • Compliance documentation: manual creation
  • Point-in-time evidence that expires
  • Annual cycle — pay again next year

Reg S-P Compliance Bundle

$9,250 – $21,250/yr
  • AI Compliance Cockpit with Reg S-P mapping
  • Continuous BAS testing (60+ controls)
  • Network threat detection (NDR)
  • Vulnerability scanning with KEV prioritization
  • Dark web monitoring: named accounts
  • TPRM: vendor scoring with 50 slots
  • AI document review for attestations
  • Continuous evidence — always current

5–16× cost compression.

Continuous compliance assurance instead of annual snapshots. Single platform. Single contract. Audit-ready on demand.


How CYFAX Protects Your Firm and Produces Compliance Evidence Simultaneously

CYFAX is not a compliance tool that happens to mention security.

It is a cybersecurity platform that produces compliance evidence as a byproduct of actually protecting your firm. The compliance output exists because the security operations are real.

Know Before It Happens

6–21
Weeks Advance Warning
3,600+
Threat Actors Profiled
500B+
Threat Objects Analyzed

ARETE does not produce a risk score. It predicts breach probability by analyzing threat actor behavior, credential exposure velocity, and industry targeting patterns. When a threat actor begins reconnaissance against financial services firms in your region, you know about it weeks before anything happens.

No other compliance platform does this. No external scanner does this. No vCISO does this. CYFAX does this.

ARETE predictive threat intelligence
VIP executive protection monitoring

Your Clients' Names Are Already Out There

20,000+
Criminal Sources Monitored
24/7
Dark Web Surveillance

VIP Monitoring watches criminal forums, stealer log ecosystems, dark web marketplaces, and Telegram channels for your partners, principals, and high-net-worth clients by name. It detects pre-attack reconnaissance — personal data searches, criminal intent chatter, credential exposure — before anything happens.

When a threat actor is researching one of your clients, you find out first. Not after the breach. Not from a vendor notification 45 days late. CYFAX finds it in the chatter before it becomes an attack.

🔍

External Attack Surface Monitoring

Continuous scanning across 500 billion+ threat objects and 20,000+ criminal sources. Identifies leaked credentials by name, exposed infrastructure, email security gaps, dark web mentions, and impersonation domains. Initial scan takes 60 minutes with zero installation required. CYFAX does this.

📊

Compliance Cockpit

Real-time governance heatmap mapping controls across Reg S-P, NIST CSF 2.0, and 350+ global frameworks simultaneously. Each control shows Compliant, Review, or Critical status. AI reviews uploaded evidence documents for fitness-for-purpose against regulatory requirements. CYFAX does this.

🏢

Third-Party Risk Management

Upload a CSV of vendor domains. Come back and review traffic-light scorecards showing risk scores, external exposures, credential status, and email vulnerabilities for every vendor in your supply chain. Reg S-P requires vendor oversight. CYFAX does this.

🛡️

PREVENT Endpoint Agent

Validates 60+ internal security controls against CIS Benchmarks and MITRE ATT&CK. Runs continuous breach attack simulation, vulnerability scanning with CVSS/KEV prioritization, and network detection and response. Deploys in approximately 10 minutes per VLAN. PREVENT does this.

Don't Have Policies? We Build Them For You.

These aren't advisory recommendations on a consultant's invoice. They are the 12 SEC-required security policies your examiner will ask for — generated in minutes, not billable hours.

12
SEC-Required Policies
Minutes
Not Billable Hours
$0
Extra Cost

Answer a short questionnaire about your firm — size, structure, custodians, data handling practices. Our AI generates all 12 policies customized to your operations. Review them, make any edits, and upload directly to the Compliance Cockpit. The attestation engine validates each policy for fitness-for-purpose against Reg S-P requirements.

The 12 policies: Written Information Security (WISP) · Incident Response Plan · Business Continuity & DR · Acceptable Use · Access Control · Data Classification · Vendor Risk Management · Security Awareness Training · Encryption & Data Protection · Change Management · Remote Access & BYOD · Data Retention & Disposal

AI-powered policy generator for RIAs

SEC Regulation S-P — Everything RIAs Need to Know

SEC Regulation S-P (17 CFR Part 248) requires registered investment advisers, broker-dealers, and investment companies to adopt written policies and procedures that address administrative, technical, and physical safeguards for the protection of customer records and information. The regulation was originally adopted in 2000 under the Gramm-Leach-Bliley Act and was significantly expanded by the 2023 amendments to include incident response programs, individual breach notification, and enhanced vendor oversight.
The 2023 amendments add three major requirements: written incident response programs with procedures for detecting, responding to, and recovering from unauthorized access to customer information; notification to affected individuals within 30 days of discovering a breach; and enhanced oversight of service providers' data handling practices with 72-hour vendor breach notification requirements. The compliance deadline is June 3, 2026.
The compliance deadline for the amended Regulation S-P requirements is June 3, 2026. After this date, SEC examiners will evaluate firms against the full amended requirements during examinations. Violation exposure is up to $2.5 million per incident.
Regulation S-P applies to registered investment advisers (RIAs), broker-dealers, investment companies, and transfer agents registered with the SEC. Any firm that collects and maintains nonpublic personal information of customers is subject to the regulation's safeguard and notification requirements.
Reg S-P requires firms to develop, implement, and maintain written incident response programs that include procedures for detecting and responding to unauthorized access to customer information, assessing the nature and scope of any incident, containing and controlling the incident, and notifying affected individuals within 30 days of discovery. A designated qualified individual must oversee the program with appropriate authority and resources.
When a firm determines that unauthorized access to customer information has occurred or is reasonably likely to have occurred, it must notify each affected individual within 30 days. The notification must include details about the incident, the types of information involved, and firm contact information.
Service providers that experience a breach involving customer information must notify the covered institution within 72 hours. Firms must ensure vendor contracts include breach notification clauses and maintain ongoing oversight of their service providers' data handling and incident response practices. The CYFAX TPRM module automates vendor risk monitoring and provides continuous assessment of vendor security posture.
Non-compliance can result in SEC enforcement actions including fines of up to $2.5 million per incident, censure, suspension, or revocation of registration, and significant reputational damage. SEC examination staff specifically evaluate Reg S-P compliance during routine and for-cause examinations.
SEC examiners request documentation across ten categories: written information security policies, evidence of a designated compliance officer, incident response plan documentation, employee training records, access control implementation evidence, monitoring and detection capabilities, business continuity plans, vendor oversight documentation, control testing records, and historical incident handling evidence. Firms unable to produce these artifacts on demand face adverse examination findings.
No. A cyber insurance policy does not satisfy any Reg S-P requirement. The SEC does not ask whether you have a cyber policy. They ask for documented incident response procedures, evidence of monitoring and detection capabilities, access controls, vendor oversight documentation, and proof that controls are regularly tested. Insurance transfers financial risk after a breach occurs. Reg S-P requires preventing and detecting breaches and maintaining documented evidence of those capabilities.
No. An external-only scan measures external hygiene — visible ports, SSL status, and email configuration. It does not test internal security controls, validate backup configurations, check endpoint protection status, verify incident response procedures, or produce the compliance evidence SEC examiners require. A high external score means nothing when the examiner asks for proof that your internal controls are functioning and your monitoring is continuous.
CYFAX auto-verifies approximately 40–50% of Reg S-P controls through external reconnaissance including credential exposure monitoring, email security validation, vulnerability detection, and vendor risk assessment. When the PREVENT endpoint agent is deployed, auto-verification increases to approximately 85% by validating 60+ internal security controls against CIS Benchmarks and MITRE ATT&CK. All verification evidence feeds directly into the Compliance Cockpit governance heatmap and is available as audit-ready documentation on demand.
PREVENT provides continuous security control validation through breach attack simulation testing 60+ controls, network detection and response monitoring for active threats including ransomware command-and-control communication, vulnerability scanning with CVSS and CISA KEV prioritization, and real-time endpoint telemetry. All detection evidence flows automatically into the Compliance Cockpit, producing continuous monitoring evidence without manual documentation effort.
Yes. CYFAX monitors 500 billion+ threat objects across 20,000+ criminal sources including dark web marketplaces, stealer log ecosystems, criminal forums, and Telegram channels. Unlike aggregate monitoring services that report numbers without names, CYFAX identifies specific named accounts with dates, sources, and active/inactive status. The VIP Monitoring module extends this to individual high-net-worth clients, detecting personal data exposure before vendors report breaches.
The Compliance Cockpit displays a real-time governance heatmap mapping security controls against multiple frameworks simultaneously. Each control is classified as Compliant (green), Review (yellow), or Critical (red) based on automated verification and uploaded evidence. The heatmap supports NIST CSF 2.0, SEC Reg S-P, NIS-2, HIPAA, PCI-DSS, 23 NYCRR 500, SOC 2, ISO 27001, and 350+ additional directives via a framework dropdown. When PREVENT is deployed, internal evidence feeds automatically, converting red and yellow indicators to green without manual uploads.
The amended regulation requires firms to conduct due diligence before engaging service providers, include contractual requirements for 72-hour breach notification, monitor vendor security practices on an ongoing basis, and maintain documentation of vendor risk assessments. The CYFAX TPRM module automates this: upload vendor domains in a CSV, receive risk scores with external exposures, credential status, and email vulnerability assessments for each vendor within hours — no vendor cooperation required.
CYFAX + PREVENT delivers comprehensive Reg S-P compliance coverage for $9,250 to $21,250 per year including automated evidence collection, continuous control validation, dark web monitoring with named accounts, vendor risk management, and the AI Compliance Cockpit. The traditional approach costs $70,000 to $110,000 or more annually. This represents a 5–16× cost compression.with continuous rather than point-in-time compliance assurance.
Average time to Reg S-P compliance readiness with CYFAX is measured in days, not months. The initial external scan takes approximately 60 minutes with zero installation. The Compliance Cockpit maps findings to Reg S-P requirements immediately. Firms can upload existing security artifacts for AI review within hours. Deploying the optional PREVENT agent takes approximately 10 minutes per VLAN and begins auto-verifying internal controls immediately. Most firms achieve 85%+ compliance verification within the first week.
Yes. The Compliance Cockpit supports 350+ global compliance directives including 23 NYCRR 500 (New York DFS), SOX, HIPAA, PCI-DSS, SOC 2, ISO 27001, NIST CSF 2.0, NIS-2, DORA, and GDPR. The governance heatmap displays compliance status across all active frameworks simultaneously through a single interface.
CYFAX is a cybersecurity platform that produces compliance evidence as a byproduct of actually protecting your firm. Compliance-only platforms automate the documentation process but do not provide threat intelligence, dark web monitoring, predictive analytics, network detection, or breach attack simulation. CYFAX monitors 500 billion+ threat objects, predicts breaches 6–21 weeks in advance, detects active network threats, and scores vendor risk — and all of that operational security evidence flows into the Compliance Cockpit automatically. The compliance output is real because the security operations are real.
The builder generates all 12 security policies SEC examiners request during Reg S-P examinations: Written Information Security Policy (WISP), Incident Response Plan, Business Continuity and Disaster Recovery, Acceptable Use, Access Control, Data Classification and Handling, Vendor Risk Management, Security Awareness Training, Encryption and Data Protection, Change Management, Remote Access and BYOD, and Data Retention and Disposal. Each policy is customized to your firm based on a short questionnaire about your size, structure, custodians, and data handling practices.
Minutes. You complete a questionnaire about your firm — approximately 15 to 20 questions covering your organizational structure, data handling practices, custodial relationships, and technology environment. The AI generates all 12 policies customized to your responses. You review, make any edits, and upload them directly into the Compliance Cockpit where the attestation engine validates each one against Reg S-P requirements.
No. The policy builder is included with the CYFAX Compliance Cockpit. There is no additional fee for generating, reviewing, or uploading policies. Traditional approaches charge $15,000 to $40,000 for a consultant to write these same documents over 8 to 12 weeks. The AI generates them in minutes at zero additional cost.
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