GLBA & Reg S-P Compliance for Investment Advisors

Yes. Investment advisors, RIAs, broker-dealers, and wealth management firms are financial institutions under the Gramm-Leach-Bliley Act because they collect and handle clients' nonpublic personal information. Which rule enforces GLBA against your firm depends on your registration. SEC-registered investment advisors and broker-dealers are subject to the SEC's Regulation S-P (17 CFR Part 248), the SEC's rule implementing GLBA. State-registered advisors, generally those below the SEC registration threshold, and advisors not required to register with the SEC fall under the FTC's jurisdiction, so the FTC Safeguards Rule (16 CFR Part 314) applies to them. The duty to protect client information is the same either way. We determine which regime governs your firm during onboarding and build one program to satisfy it.

It depends on where you are registered. SEC-registered investment advisors and broker-dealers are governed by the SEC's Regulation S-P, including the 2024 amendments that add an incident response program and a customer breach-notification requirement. Advisors registered at the state level, and advisors not required to register with the SEC, fall under the FTC and its Safeguards Rule instead. Firms sometimes assume one federal rule covers everyone, but the jurisdiction split is real. We confirm your registration and applicable regime during onboarding, then build a single security program mapped to whichever rule governs you so there is no gap and no duplicated effort.

In 2024 the SEC adopted amendments to Regulation S-P that meaningfully expanded what SEC-covered firms must do. The two central additions are a written incident response program and a customer breach-notification requirement. Covered firms must be able to detect, respond to, and recover from unauthorized access to or use of customer information, and must notify affected individuals when their sensitive customer information is, or is reasonably likely to have been, accessed or used without authorization. The notification standard is generally around 30 days, with compliance dates phased in for larger and smaller firms. The amendments also extend certain protections to a broader set of customer information. We build the incident response program and the notification workflow so a real event is handled inside the required window.

Across both Reg S-P and the FTC Safeguards Rule, the core elements are consistent. You need a written information security program and a single accountable individual overseeing it. You need a documented risk assessment covering client information in your custodial, CRM, portfolio-management, and email systems. You need access controls with multi-factor authentication and encryption of client information in transit and at rest. You need ongoing monitoring, testing, and audit logging of access to that information, plus oversight of the service providers that handle it. Finally you need an incident response program and, for SEC-covered firms under the 2024 amendments, a customer breach-notification process. The FTC Safeguards Rule frames several of these through a designated Qualified Individual and a specific testing cadence. We map the exact requirements to your regime and deliver each one.

Business email compromise and fraudulent wire or disbursement requests are among the most damaging threats a wealth management firm faces. A single spoofed client email requesting a distribution to a new account can move significant funds to an attacker. The controls GLBA requires are the same controls that blunt these schemes. Multi-factor authentication makes the email-account takeover that starts most of these attacks far harder. Encryption and access controls protect the account details attackers are hunting for. Email security reduces the phishing that seeds the initial compromise. On top of the required controls, we help you document out-of-band verification procedures so any disbursement or change to client banking instructions is confirmed through a known channel before funds move. Compliance and fraud prevention are the same work here.

Yes. Cybersecurity and the protection of customer records have been recurring focus areas in SEC examinations of investment advisors and broker-dealers, and Regulation S-P is squarely within that scope. Examiners look for a real, documented program, evidence that controls are in place and operating, oversight of service providers, and, under the 2024 amendments, an incident response program and notification process. A program that reads as boilerplate does not survive that scrutiny. We build and document the program to reflect what is actually running in your environment, and we keep the evidence current so an examination request is answered rather than scrambled for.

We deliver the program end to end. That starts with determining whether Reg S-P or the FTC Safeguards Rule governs your firm, then a gap analysis, a written risk assessment, and the written information security program and supporting policies. It includes implementation of the technical controls: MFA, encryption, access controls, logging, and endpoint and email security across your custodial, CRM, and portfolio-management environment. It covers monitoring and testing, security awareness training, vendor oversight, and the incident response and customer breach-notification workflow the applicable rule requires. We then manage the program on an ongoing basis so it stays current as your registration status and the rules change. We serve commercial clients across Texas, Tennessee, and the United States.