What Is Regulation S-P?
Regulation S-P requires two main things: a privacy notice given to clients at the start of the relationship (and periodically afterward, depending on firm practices) explaining what personal information the firm collects and how it’s shared, and a written information security program describing the administrative, technical, and physical safeguards the firm uses to protect that data. A 2024 amendment to the rule also added an incident response program requirement, including client notification obligations within a specific timeframe if sensitive information is compromised.
Firms need documentation showing not just that a privacy policy exists, but that it’s actually distributed to clients and followed operationally.