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Regulation S-P guide

Reg S-P incident response program template for small RIAs

Amended Regulation S-P now applies to smaller SEC-registered advisers. Here is what it requires in plain English, and editable templates that map to each piece.

  • Plain English
  • Editable Word & Excel
  • Free self-assessment

Updated October 18, 2026 · Get the free self-assessment

The requirement

What amended Regulation S-P requires, in plain English

The SEC amended Regulation S-P in 2024. Every covered firm now needs a written incident response program that is reasonably designed to detect, respond to and recover from unauthorized access to or use of customer information. The program must assess what happened, contain and control the incident, and notify affected people.

If sensitive customer information was, or is reasonably likely to have been, accessed or used without authorization, you must notify affected individuals as soon as practicable and no later than 30 days after you become aware of it. You can skip notice only if a reasonable investigation shows substantial harm or inconvenience is not reasonably likely, and you need to document that determination.

You also need written policies to oversee service providers such as custodians, CRMs and IT firms. They must be required to protect customer information and to tell you within 72 hours of becoming aware of a breach in their systems that affects your customers.

Finally, the amendments add recordkeeping requirements for the program, investigations, notice decisions and service provider arrangements.

Requirement by requirement

Where each requirement is covered in the Financial Advisor CyberSecure kit

Every document is editable Word or Excel. Items marked Pro are in the Professional Edition only.

RequirementWhat it means for youKit documents
Written incident response programA written program to detect, respond to and recover from incidents.
  • Incident Response & Customer Notification PolicyStarter & Pro
  • Incident Response Plan & PlaybooksPro
Assess and containFigure out scope and which systems and data were hit, then stop the spread.
  • Incident Response Plan & PlaybooksPro
  • FORM-06 Incident Intake FormPro
30-day customer noticeNotify affected individuals unless a documented determination says no harm is likely.
  • FORM-09 Customer Notification Determination WorksheetPro
  • Client Security & Money Movement NoticeStarter & Pro
Service provider oversight and 72-hour noticeVet providers and require them to notify you within 72 hours.
  • Service Provider & Custodian Oversight PolicyStarter & Pro
  • FORM-07 Service Provider Security QuestionnairePro
Safeguards and disposalPolicies that protect customer records and dispose of them properly.
  • Information Security Program & Governance PolicyStarter & Pro
  • Records Retention & Secure Disposal PolicyStarter & Pro
Identity theft red flags (Reg S-ID)A program to spot and respond to identity theft warning signs.
  • Identity Theft Red Flags Program PolicyPro
Recordkeeping and annual reviewKeep the written records and review the program each year.
  • FORM-10 Annual Cybersecurity Review & Management ReportPro
  • Financial Advisor CyberSecure Professional ToolkitPro
Practice itWalk through a realistic incident with your team before it happens.
  • Tabletop Exercise KitPro
See a sample page

What the Incident Response Plan & Playbooks looks like

Plain-language templates with bracketed fields for your details, policy IDs that stay the same when you upgrade, and a footer reminding you to customize before use.

  • Download right after checkout
  • Edit in Microsoft Word, Google Docs or any word processor
  • One-time price: Starter $149 · Professional $249
Sample first page of the Financial Advisor CyberSecure Incident Response Plan & Playbooks template
Page 1 of the Financial Advisor incident response plan, with key contacts and severity levels to fill in.
What's inside

Every file in each edition

Policy numbers carry over from the Starter Kit to the Professional Edition, so you can start small and upgrade without renumbering.

Starter Kit

$149

24 editable files

Policies 15

  • FA-CYB-001Information Security Program & Governance Policy
  • FA-CYB-002Risk Assessment & Customer Information Inventory Policy
  • FA-CYB-003Access Control & Least Privilege Policy
  • FA-CYB-004Multi-Factor Authentication Password Policy
  • FA-CYB-005Encryption & Secure Client Communication Policy
  • FA-CYB-006Acceptable Use & Workstation Security Policy
  • FA-CYB-007Email Security, Phishing & Impersonation Policy
  • FA-CYB-008Personnel Security & Confidentiality Policy
  • FA-CYB-009Security Awareness & Training Policy
  • FA-CYB-010Physical Security & Clean Desk Policy
  • FA-CYB-011Backup, Recovery & Business Continuity Policy
  • FA-CYB-012Records Retention & Secure Disposal Policy
  • FA-CYB-013Service Provider & Custodian Oversight Policy
  • FA-CYB-014Incident Response & Customer Notification Policy
  • FA-CYB-015Remote Work & Mobile Device Policy

Plans, guides & assessments 8

  • WordImplementation Guide
  • WordStaff Cybersecurity Quick Guide
  • WordIncident Response Plan
  • WordWritten Information Security Program (WISP)
  • WordClient Security & Money Movement Notice
  • Word30-60-90 Day Action Plan
  • Word50-Point Cybersecurity Checklist
  • WordCybersecurity Maturity Assessment

Workbook 1

  • ExcelFinancial Advisor CyberSecure Toolkit

Professional Edition

$249

42 editable files

Policies 21

  • FA-CYB-001Information Security Program & Governance Policy
  • FA-CYB-002Risk Assessment & Customer Information Inventory Policy
  • FA-CYB-003Access Control & Least Privilege Policy
  • FA-CYB-004Multi-Factor Authentication Password Policy
  • FA-CYB-005Encryption & Secure Client Communication Policy
  • FA-CYB-006Acceptable Use & Workstation Security Policy
  • FA-CYB-007Email Security, Phishing & Impersonation Policy
  • FA-CYB-008Personnel Security & Confidentiality Policy
  • FA-CYB-009Security Awareness & Training Policy
  • FA-CYB-010Physical Security & Clean Desk Policy
  • FA-CYB-011Backup, Recovery & Business Continuity Policy
  • FA-CYB-012Records Retention & Secure Disposal Policy
  • FA-CYB-013Service Provider & Custodian Oversight Policy
  • FA-CYB-014Incident Response & Customer Notification Policy
  • FA-CYB-015Remote Work & Mobile Device Policy
  • FA-CYB-016Identity Theft Red Flags Program Policy
  • FA-CYB-017Money Movement & Account Change Verification Policy
  • FA-CYB-018Vulnerability Management & Security Testing Policy
  • FA-CYB-019Generative AI, Electronic Communications & Cloud Policy
  • FA-CYB-020Privacy Notice & Information Sharing Policy
  • FA-CYB-021AI Governance Policy

Plans, guides & assessments 10

  • WordProfessional Edition Implementation Guide
  • WordIncident Response Plan & Playbooks
  • WordTabletop Exercise Kit
  • Word30-60-90 Day Action Plan
  • WordStaff Cybersecurity Quick Guide
  • WordWritten Information Security Program (WISP)
  • WordClient Security & Money Movement Notice
  • Word50-Point Cybersecurity Checklist
  • WordCybersecurity Maturity Assessment
  • Word50-Question Financial Advisor Cybersecurity Self-Assessment

Forms & templates 10

  • FORM-01Money Movement & Account Change Verification Form
  • FORM-02Access Request Form
  • FORM-03Staff Offboarding Checklist
  • FORM-04Software, SaaS & AI Tool Request Form
  • FORM-05Security Exception Request
  • FORM-06Incident Intake Form
  • FORM-07Service Provider Security Questionnaire
  • FORM-08Confidentiality Policy Acknowledgment Form
  • FORM-09Customer Notification Determination Worksheet
  • FORM-10Annual Cybersecurity Review & Management Report

Workbook 1

  • ExcelFinancial Advisor CyberSecure Professional Toolkit
Questions

Frequently asked questions

When did smaller RIAs have to comply with amended Reg S-P?

June 3, 2026. Larger entities, including RIAs with $1.5 billion or more in assets under management, had to comply by December 3, 2025.

How fast do we have to notify clients?

As soon as practicable, and no later than 30 days after becoming aware that sensitive customer information was, or is reasonably likely to have been, accessed or used without authorization.

Can we decide notice isn't needed?

Yes, if a reasonable investigation finds that substantial harm or inconvenience is not reasonably likely. Document how you reached that conclusion; the kit includes a worksheet for it.

Do we have to change our custodian and vendor contracts?

The rule requires written policies that make service providers protect customer information and notify you within 72 hours. It does not expressly require a contract clause, but many firms add one. Talk to your counsel.

Is this legal or compliance advice?

No. These are editable templates and plain-English education, not a compliance determination. Your CCO and counsel should review them.

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Start with the Starter Kit or get every policy, form and workbook in the Professional Edition. Policy numbers carry over if you upgrade.

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Sources

  1. SEC final rule: Regulation S-P amendments (Release 34-100155)
  2. Davis Wright Tremaine: smaller entities must comply by June 3, 2026

This guide is plain-English education, current as of October 18, 2026. It is not legal advice, an audit or a compliance determination, and Cybriva is not affiliated with any regulator or standards body named here. Rules change and vary by state; confirm how they apply to you with your attorney or compliance advisor.

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