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ARTICLE · 22 OCTOBER 2025

Privacy, Cyber & Data Strategy Advisory | Countdown To Expanded Obligations Under Reg S-P

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The compliance deadline for the Securities and Exchange Commission's amended Regulation S-P is fast approaching, requiring financial institutions to meet new safeguards for customer data privacy and incident response.

United StatesPrivacy
Katherine Doty Hanniford
Katherine Doty Hanniford
Kristen Bartolotta
Kristen Bartolotta

Executive Summary

The compliance deadline for the Securities and Exchange Commission's amended Regulation S-P is fast approaching, requiring financial institutions to meet new safeguards for customer data privacy and incident response. Our Privacy, Cyber & Data Strategy Team outlines how the rule broadens coverage, heightens service-provider oversight, and adds recordkeeping requirements consistent with today's cybersecurity standards.

  • Larger financial institutions must comply with the amended Reg S-P by December 3, 2025
  • New requirements strengthen incident response, customer notification, and service-provider oversight
  • Expanded definitions provide broader protection for customer and consumer data

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