
Regulation S-P in 2026: The Incident-Response, Customer-Notice, and Recordkeeping Checklist for Small RIAs and Broker-Dealers
The SEC's amended Regulation S-P has applied to smaller covered institutions since June 3, 2026, requiring a written incident-response program, customer notice within 30 days of awareness, and 72-hour service-provider breach escalation. A practical checklist for small RIAs, broker-dealers, and transfer agents covering the notice decision, vendor oversight, disposal rules, and the records that prove each step.










