--- title: Reg S-P Deadline Has Come and Gone… What Now? description: Reg S-P compliance is crucial for protecting client information. Ensure your policies are updated and ready for SEC examinations post-deadlines. image: https://blog.stpis.com/hubfs/shutterstock_1329163259.jpg --- [![STP\_header\_logo](https://blog.stpis.com/hs-fs/hubfs/STP%20Growth%20Child/STP_header_logo.png?width=75&height=94&name=STP_header_logo.png "STP_header_logo")](http://stpis.com) - [FAQs](https://stpis.com/faqs-fund-administration-compliance-managed-services/) - [About](https://stpis.com/about/) - [About STP](https://stpis.com/about/) - [History](https://stpis.com/history/) - [Team](https://stpis.com/people/) - [STP Careers](https://stpis.com/careers/) - [STP Culture](https://stpis.com/careers/culture/) - [Benefits](https://stpis.com/careers/benefits/) - [Diversite, Equity, Inclusion & Belonging (DEIB)](https://stpis.com/careers/deib/) - [Hiring Process](https://stpis.com/careers/hiring-process/) [Portal Login](https://portal.stpis.com/) [Connect With Us](https://stpis.com/connect-with-us/) - [Who We Serve](https://stpis.com/who-we-serve/) - [Institutional Managers Investment operations services and innovative software for the front, middle, and back office.](https://stpis.com/who-we-serve/institutional-managers/) - [Wealth Managers Custom and turnkey asset management programs to grow assets and support clients.](https://stpis.com/who-we-serve/wealth-managers/) - [Emerging Managers Best-in-class full service solution to springboard your startup to the next level.](https://stpis.com/who-we-serve/emerging-managers/) - [Private Fund Advisors Comprehensive suite of fund administration, compliance, account and investor reporting services](https://stpis.com/who-we-serve/private-fund-advisors/) - [What We Do](https://stpis.com/services/) - [Investment Operations Outsourcing End-to-end investment operations and trading services.](https://stpis.com/services/investment-operations-outsourcing/) - [Fund Services Complete suite of services that deliver best-in-class fund administration.](https://stpis.com/services/fund-administration-services/) - [Compliance Services Get oversight that keeps you compliant and ready for changing regulatory requirements.](https://stpis.com/services/compliance/) - [Managed Services Designed to reduce operational burden, streamline workflows, and help you scale without adding headcount.](https://stpis.com/services/managed-services/) - [Trade Settlements Streamline processes, increase efficiency, and mitigate risk with post-trade settlement services.](https://stpis.com/services/trade-settlements/) - [Reconciliation Services Automate reconciliation tasks and strengthen oversight with reconciliation dashboards.](https://stpis.com/services/reconciliation/) - [BluePrint](https://stpis.com/blueprint/) - [Why STP](https://stpis.com/why-stp/) - [STP Knowledge Hub](https://stpis.com/stp-knowledge-hub/) - [Perspectives Fresh, original STP content written by members of our team, covering a broad range of topics.](https://blog.stpis.com/blog) - [STP in the News Our take on industry articles and topics written by our colleagues across the financial services space.](https://stpis.com/stp-knowledge-hub/in-the-news/) - [Case Studies Explore real-world success stories that highlight how we've helped clients overcome challenges, drive growth, and achieve their goals.](https://stpis.com/stp-knowledge-hub/case-studies/) - [Strategic Insights Stay ahead of regulatory changes, operational challenges, and industry shifts. Download our strategic insights to equip your firm with expert guidance on compliance, operations, and growth strategies.](https://stpis.com/stp-knowledge-hub/strategic-insights/) Aug 2026 # Reg S-P Deadline Has Come and Gone… What Now? ![Picture of Deanna Hutchinson](https://blog.stpis.com/hs-fs/hubfs/Deanna%20Hutchinson.png?width=50&name=Deanna%20Hutchinson.png) [Deanna Hutchinson](https://blog.stpis.com/blog/author/deanna-hutchinson) Share: [facebook-f icon](http://www.facebook.com/share.php?u=https://blog.stpis.com/blog/reg-s-p-deadline-has-come-and-gone-what-now) [linkedin-in icon](http://www.linkedin.com/shareArticle?mini=true&url=https://blog.stpis.com/blog/reg-s-p-deadline-has-come-and-gone-what-now) [Twitter icon](https://twitter.com/intent/tweet?url=https://blog.stpis.com/blog/reg-s-p-deadline-has-come-and-gone-what-now) [pinterest-p icon](http://pinterest.com/pin/create/link/?url=https://blog.stpis.com/blog/reg-s-p-deadline-has-come-and-gone-what-now) [envelope icon](mailto:?body=https://blog.stpis.com/blog/reg-s-p-deadline-has-come-and-gone-what-now) Reg S-P Deadline Has Come and Gone… What Now? 3:07 Regulation S-P had two go-live dates: December 3, 2025, for firms over $1.5 billion and June 3, 2026, for firms under that. Whether you updated your policies and procedures (P&Ps) in December or June doesn’t change the fact that your P&Ps should be solidly in place. Let’s take a moment to review: **Why Reg S-P Amendment?** Recognizing the expanded use of technology and the increased risks to non-public personal information (NPI), the SEC amended Regulation S-P. Per the SEC’s press release on May 16, 2024, its reason for an adopted amendment was to “modernize and enhance the rules that govern the treatment of consumers’ nonpublic personal information by certain financial institutions… to address the expanded use of technology and corresponding risks that have emerged since 2000”. Simply put, consumer NPI can be found in a myriad of places – many of which are unsecured, purchased by nefarious entities, or stolen and placed on the dark web – and the SEC wants to ensure that firms handling consumer information, including RIAs, have appropriate safeguards in place to protect client information and documented policies and procedures to respond, should that information be compromised. Among other requirements, the amended Reg S-P required covered firms to develop, implement, and maintain written policies and procedures for an incident response plan; provide notice to affected individuals as soon as practicable, but no later than 30 days after becoming aware of certain unauthorized access to, or use of, sensitive customer information; and maintain records documenting compliance with the amendments, including oversight of providers (this is your vendor due diligence). **What Should Be in Place Today** Whether in December 2025 or June 2026, your *P&Ps should have been updated to reflect an incident response plan* to notify clients of qualifying incidents within the required timeframe. Additionally, *oversight of your third-party providers (vendor due diligence) should now include vendor confirmation that they will alert you, the steward of your client’s NPI, as soon as possible, but no later than 72 hours after becoming aware of an incident*. This piece is critical: receiving confirmation from your vendor that they will adhere to this requirement is paramount. Additionally, having that confirmation in writing and maintained as part of your books and records and incorporated into your incident response plan, is imperative. Of course, let’s not forget documentation. Updating your policies and procedures is only part of compliance. Firms should also be prepared to demonstrate implementation through employee training, testing of incident response procedures, vendor oversight records, cybersecurity risk assessments, and evidence that notifications can be delivered within required timeframes. During an SEC examination, firms should expect to provide documentation supporting their Reg S-P compliance program. 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