What Is a Cybersecurity Policy for RIAs?

While cybersecurity isn’t governed by a single standalone SEC rule the way some other compliance areas are, it intersects with Regulation S-P’s information security program requirement and is a consistent focus in SEC examination priorities. A well-built cybersecurity policy typically addresses access controls and authentication, data encryption, employee training, third-party vendor due diligence (particularly for custodians and software providers), and a documented incident response plan.

Firms benefit from grounding their policy in an actual cybersecurity risk assessment rather than adopting a generic template, since examiners increasingly expect evidence that the policy reflects the firm’s real technology environment and known vulnerabilities.