--- title: Regulatory Round-Up October 2026 description: RIAs should review compliance alignment, cybersecurity readiness, and third-party oversight ahead of SEC exams and Regulation S-P changes in 2026. image: https://blog.truewest-consulting.com/hubfs/TW-OctoberRoundUp.jpg --- [![TrueWest-WhiteLogo-Transparent](https://blog.truewest-consulting.com/hs-fs/hubfs/Branding/TrueWest-WhiteLogo-Transparent.png?width=2000&height=390&name=TrueWest-WhiteLogo-Transparent.png "TrueWest-WhiteLogo-Transparent")](https://truewest-consulting.com) [![TrueWest-WhiteLogo-Transparent](https://blog.truewest-consulting.com/hs-fs/hubfs/Branding/TrueWest-WhiteLogo-Transparent.png?width=2000&height=390&name=TrueWest-WhiteLogo-Transparent.png "TrueWest-WhiteLogo-Transparent")](https://truewest-consulting.com) - [About](https://www.truewest-consulting.com/about) - [Technology](https://www.truewest-consulting.com/technology) - [Services](https://www.truewest-consulting.com/services) - Compliance - [RIA Compliance](https://www.truewest-consulting.com/services/ria-compliance) - [Private Fund Compliance](https://www.truewest-consulting.com/services/private-fund-compliance) - [Legal](https://www.truewest-consulting.com/services/legal) - [IT Operations & Governance](https://www.truewest-consulting.com/services/it-operations-and-governance) - [Finance](https://www.truewest-consulting.com/services/finance) - [News & Insights](https://blog.truewest-consulting.com/news-insights) - [Contact](https://www.truewest-consulting.com/contact) [Tech Portal Login](https://truewest.greenboard.com/) [Schedule a Call](https://www.truewest-consulting.com/schedule-a-call) [Tech Portal Login](https://truewest.greenboard.com/) [Schedule a Call](https://www.truewest-consulting.com/schedule-a-call) - [About](https://www.truewest-consulting.com/about) - [Technology](https://www.truewest-consulting.com/technology) - [Services](https://www.truewest-consulting.com/services) - Compliance - [RIA Compliance](https://www.truewest-consulting.com/services/ria-compliance) - [Private Fund Compliance](https://www.truewest-consulting.com/services/private-fund-compliance) - [Legal](https://www.truewest-consulting.com/services/legal) - [IT Operations & Governance](https://www.truewest-consulting.com/services/it-operations-and-governance) - [Finance](https://www.truewest-consulting.com/services/finance) - [News & Insights](https://blog.truewest-consulting.com/news-insights) - [Contact](https://www.truewest-consulting.com/contact) [Tech Portal Login](https://truewest.greenboard.com/)[Schedule a Call](https://www.truewest-consulting.com/schedule-a-call) [Regulatory Round Up](https://blog.truewest-consulting.com/news-insights/tag/regulatory-round-up) # Regulatory Round-Up October 2026 [![True West](https://blog.truewest-consulting.com/hs-fs/hubfs/Branding/Graphics/TrueWest-Icon-In-Circle.png?width=40&height=40&name=TrueWest-Icon-In-Circle.png)](https://blog.truewest-consulting.com/news-insights/author/true-west) by [True West](https://blog.truewest-consulting.com/news-insights/author/true-west) Oct 08 2026 Regulatory Round-Up October 2026 2:33   ## **CYBERSECURITY: A CRITICAL COMPLIANCE PRIORITY FOR RIAs** Cybersecurity is no longer simply an information-technology issue for registered investment advisers. It is **a compliance, fiduciary, operational, privacy, vendor-management, and business-continuity issue.** Investment advisers maintain exactly the type of information cybercriminals seek: Social Security numbers, account information, financial records, tax documents, email addresses, wire instructions, passwords, and information regarding clients’ assets and financial institutions. The SEC continues to treat cybersecurity and the protection of client information as significant examination concerns. For fiscal year 2026, the SEC Division of Examinations identified cybersecurity practices, Regulation S-P, Regulation S-ID, third-party vendor oversight, ransomware preparedness, access controls, data-loss prevention, artificial intelligence risks, incident response, and operational resiliency as examination areas. #### **THE TAKEAWAY** **Cybersecurity cannot exist only on paper.** Firms should be able to demonstrate that their cybersecurity program is implemented, tested, documented, and periodically improved. ### **THE CYBER THREAT CONTINUES TO GROW** Recent cybersecurity statistics reinforce why regulators remain focused on this area. Verizon’s 2026 Data Breach Investigations Report found that software vulnerabilities, ransomware, social engineering, and third-party involvement continue to play significant roles in cybersecurity incidents. Third-party risk is particularly important for RIAs, which increasingly depend on portfolio-management systems, CRMs, financial-planning applications, custodians, cloud providers, outsourced IT firms, compliance platforms, AI applications, and other technology vendors. The FBI also continues to report substantial losses associated with cybercrime, including Business Email Compromise and other forms of financial fraud. While national statistics often include organizations much larger than a typical RIA, smaller advisory firms may have even less capacity to absorb the costs associated with an incident including forensic investigations, legal expenses, client notifications, operational downtime, regulatory inquiries, reputational damage, and technology remediation. ### **REGULATION S-P: A KEY DEVELOPMENT FOR RIAs** One of the most significant recent cybersecurity-related developments for SEC-registered investment advisers is the SEC’s amendment to **Regulation S-P**, which governs the privacy and safeguarding of customer information. The SEC adopted substantial amendments to Regulation S-P in May 2024. Among other requirements, covered institutions must maintain written policies and procedures for an incident-response program reasonably designed to detect, respond to, and recover from unauthorized access to or use of customer information. The amended rule also establishes customer-notification requirements. Subject to limited exceptions, affected individuals generally must be notified as soon as practicable, but no later than 30 days after the firm becomes aware that unauthorized access to or use of customer information has occurred or is reasonably likely to have occurred. Compliance deadlines were December 3, 2025, for larger entities and June 3, 2026, for smaller entities. As a result, SEC-registered investment advisers of all sizes should now be operating under the amended Regulation S-P requirements. **This is no longer simply an implementation project. It is an examination issue.** ### **CCO TOOL OF THE MONTH** [**Regulation S-P: Client Notification Decision Tree**](https://blog.truewest-consulting.com/hubfs/True%20West_Reg%20S-P%20Flow%20Chart.pdf) Use this month’s CCO Tool to help evaluate whether an incident involving customer information may trigger notification considerations under Regulation S-P. ### **KEY FEDERAL REQUIREMENTS AFFECTING RIA CYBERSECURITY** #### **Regulation S-P — Safeguarding Client Information** Regulation S-P requires safeguards surrounding customer records and information and, following the 2024 amendments, requires written incident-response procedures and establishes breach-notification requirements. #### **Advisers Act Rule 206(4)-7 — Compliance Program Rule** SEC-registered advisers must adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act, conduct an annual review of those policies and procedures, and designate a Chief Compliance Officer. Cybersecurity risks that could cause violations of the Advisers Act or other applicable requirements should therefore be incorporated into the firm’s compliance risk assessment and annual review. #### **Regulation S-ID — Identity Theft Red Flags** Firms subject to Regulation S-ID must maintain an appropriate Identity Theft Prevention Program for covered accounts. The SEC’s 2026 examination priorities specifically identify account takeovers, fraudulent transfers, identity-theft red flags, and employee training as examination considerations. #### **Advisers Act Rule 204-2 — Books and Records** RIAs remain responsible for maintaining required books and records. Cybersecurity incidents, ransomware, system failures, vendor failures, or corrupted backups can therefore create regulatory problems beyond the breach itself if required records become unavailable. #### **Advisers Act Sections 206(1) and 206(2) — Anti-Fraud and Fiduciary Obligations** Advisers owe fiduciary obligations to clients and must avoid fraudulent or deceptive conduct. Cybersecurity controls can intersect with these obligations when client instructions, confidential information, conflicts, disclosures, or client assets are affected. ### **WHAT DID NOT BECOME LAW** Firms should also understand one important regulatory development that **did not** move forward. In 2022, the SEC proposed a separate Cybersecurity Risk Management Rule for investment advisers, including proposed Rule 206(4)-9. In June 2025, the SEC withdrew that proposal rather than adopting it. That withdrawal should **not** be interpreted as a reduction in the SEC’s cybersecurity focus. The amended Regulation S-P is now effective, and the SEC’s 2026 examination priorities make clear that cybersecurity, incident response, vendor oversight, identity theft, and protection of client information remain significant regulatory concerns. ### **VENDOR REVIEW** #### **Outsourcing Technology Does Not Outsource Responsibility** One of the most common weaknesses in cybersecurity programs is assuming that outsourcing technology also outsources responsibility. **It does not.** An RIA may rely on an outside IT provider to prepare its Written Information Security Program (WISP), monitor endpoints, administer Microsoft 365, manage backups, or conduct penetration testing. Those services can be extremely valuable—but the firm should understand exactly what the provider is responsible for and what remains with the adviser. Your firm should know: **Who monitors security alerts?Who disables compromised accounts?Who determines whether client information was accessed?Who contacts the cybersecurity insurance carrier?Who preserves forensic evidence?Who coordinates required notifications?Who has authority to activate the incident-response plan?** Vendor contracts and cybersecurity questionnaires should not simply be collected and filed away. Firms should identify critical vendors, understand what information those vendors maintain, periodically reassess significant providers, and develop contingency plans for vendors whose failure could materially disrupt advisory operations. #### **THE TAKEAWAY** Vendors can support your cybersecurity program. They do not replace your firm’s responsibility to understand, oversee, and document how that program operates. ### **A NEW CYBERSECURITY RISK: ARTIFICIAL INTELLIGENCE** Artificial intelligence creates meaningful opportunities for advisory firms but it also introduces a new information-security challenge. Employees can move confidential information outside the firm’s controlled environment in seconds. Copying a client portfolio, tax return, financial plan, Social Security number, internal email, investment committee memorandum, or spreadsheet into an unapproved AI platform may effectively provide that information to an outside system. RIA cybersecurity policies should therefore address more than traditional cybersecurity. Firms should consider **AI governance, approved applications, confidential-data restrictions, employee training, access controls, and vendor diligence.** ### **THE QUESTION TO ASK** *“If we suffer a cybersecurity incident tomorrow, can we demonstrate that we were prepared?”* ### **SEC ENFORCEMENT REMINDER** #### **Form 13F Filing Obligations** In September 2026, the SEC announced a **$500,000 settlement** with a registered investment adviser and broker-dealer for failing to timely file required Form 13F reports. The SEC found that the firm had exercised investment discretion over more than $100 million in reportable securities and therefore was required to file quarterly Form 13F reports. Despite internal compliance recommendations that the filings be made, the firm did not begin filing until several years after the obligation arose. The action is an important reminder that firms should have controls designed to: - Monitor whether assets under investment discretion exceed the **$100 million Form 13F threshold**. - Reassess filing obligations when assets, investment strategies, or organizational structures change. - Maintain a documented quarterly filing calendar. - Escalate unresolved compliance recommendations to senior management. - Confirm required EDGAR filings are actually submitted and accepted. - Separately monitor whether trading activity could trigger **Form 13H large-trader filing obligations**, since those thresholds are based on transaction activity rather than AUM. #### **COMPLIANCE TAKEAWAY** Identifying a filing obligation is only the first step. Firms should also be able to demonstrate that filing responsibilities are assigned, compliance recommendations are tracked and escalated, and required filings are completed on time. **True West Client Note:** If your firm is not currently filing Form 13F, True West will include a threshold review in our November testing to evaluate whether the firm crossed the applicable threshold during 2026 and may need to begin filing in 2027. ### **TECH CORNER** #### **Meet Your True West Tech Resource: Bridget Katz** #### **True West Onboarding & Greenboard Tech Support** Need help navigating Greenboard? Bridget supports True West clients with **Greenboard onboarding, troubleshooting, and training.** Whether you’re a new Greenboard administrator, onboarding new employees, or simply need a refresher, you can schedule **on-demand Greenboard Admin and/or User Training** anytime. **Schedule Greenboard Training with Bridget:** [https://meetings.hubspot.com/bridget-katz](https://meetings.hubspot.com/bridget-katz) **True West Tech Support:** TechSupport@TrueWest-Consulting.com ### **NEW IN GREENBOARD** #### **Incident Response Log** Greenboard now includes an **Incident Response Log** designed to help firms document and manage cybersecurity and information-security incidents in one centralized location. #### **WHY IT MATTERS** Maintaining a detailed incident record helps your firm document its response from initial discovery through remediation and closure and creates a centralized record when you need it most. **Questions?** Contact the True West Compliance Team to discuss any of the topics covered in this month's Regulatory Round-Up. 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All Rights Reserved. - [Privacy Policy](https://45187591.hs-sites.com/privacy-policy) ![Nancy\_Headshot-min](https://blog.truewest-consulting.com/hs-fs/hubfs/Website%20Imagery/Headshots/Nancy_Headshot-min.jpg?width=1575&height=1575&name=Nancy_Headshot-min.jpg) ## Nancy Harry Founder Nancy is a founding Member at True West. She brings over 20 years of experience in the financial industry with a concentrated focus in regulatory compliance consulting for registered investment advisory firms. She has a passion for working with clients in developing their compliance programs and assists firms with building a true culture of compliance. Nancy strives to keep a simple and straightforward approach to running an efficient compliance program. [mailto:nancy.harry@truewest-consulting.com](mailto:nancy.harry@truewest-consulting.com) ![Kari\_Headshot-min](https://blog.truewest-consulting.com/hs-fs/hubfs/Website%20Imagery/Headshots/Kari_Headshot-min.jpg?width=225&height=225&name=Kari_Headshot-min.jpg) ## Kari Thiessen Founder Kari is a founding Member at True West. She brings nearly 30 years of experience in the financial services industry with a history in regulatory tax compliance, tax planning, economics and supply chain consulting. Kari takes pride in developing practical and innovative solutions for clients. Kari brings a broad and deep set of skills for any business, corporate or single person shop. [mailto:kari.thiessen@truewest-consulting.com](mailto:kari.thiessen@truewest-consulting.com) ![SigridAlegri\_TrueWest B&W-1](https://blog.truewest-consulting.com/hs-fs/hubfs/SigridAlegri_TrueWest%20B%26W-1.jpeg?width=1575&height=1575&name=SigridAlegri_TrueWest%20B%26W-1.jpeg) ## Sigrid Alegria Associate Sigrid is an Associate at True West Consulting, bringing with her nearly a decade of experience in the legal and compliance sectors. Her background includes roles as an in-house compliance associate, as well as experience with prominent firms such as Goldman Sachs & Co. Sigrid has developed a strong expertise in regulatory compliance, with a particular focus on evolving Registered Investment Advisor (RIA) regulations. At True West, she leverages her comprehensive knowledge to provide operational support to a diverse range of clients, helping them navigate complex compliance challenges and stay ahead of regulatory changes." [mailto:Trish.Gallagher@truewest-consulting.com](mailto:Trish.Gallagher@truewest-consulting.com) ![Caroline\_Headshot-min](https://blog.truewest-consulting.com/hs-fs/hubfs/Website%20Imagery/Headshots/Caroline_Headshot-min.jpg?width=1575&height=1575&name=Caroline_Headshot-min.jpg) ## Caroline Iannucci Associate Caroline is a Compliance Associate at True West. Caroline brings with her 10 years of Wall Street experience and broad based knowledge of the financial markets. As an institutional equity salesperson, she covered both hedge funds and mutual funds, specializing in public equities and private stock offerings. [mailto:caroline.iannucci@truewest-consulting.com](mailto:caroline.iannucci@truewest-consulting.com) ![TrueWest-Headshot-Carliss-min](https://blog.truewest-consulting.com/hs-fs/hubfs/TrueWest-Headshot-Carliss-min.jpg?width=225&height=225&name=TrueWest-Headshot-Carliss-min.jpg) ## Carliss Marshall Associate Carliss is a Compliance Associate at True West Consulting with six plus years of compliance experience. She has worked both as a member of an in-house compliance team and as a compliance consultant responsible for multiple clients. Carliss has experience in a variety of compliance focus areas, with extensive experience in regulatory filings. She has worked with both registered and unregistered investment advisory firms, ensuring all aspects of their compliance programs run smoothly and all regulatory requirements are met.   [mailto:carliss.marshall@truewest-consulting.com](mailto:carliss.marshall@truewest-consulting.com) ![Sara\_Sparks-min](https://blog.truewest-consulting.com/hs-fs/hubfs/Website%20Imagery/Headshots/Sara_Sparks-min.jpg?width=225&height=225&name=Sara_Sparks-min.jpg) ## Sara Sparks Consultant Sara is a seasoned Compliance Consultant at True West specializing in registered investment advisory firms. She offers guidance and best practices on constantly changing securities division regulations and ensures firms are prepared for regulatory examinations. Sara has experience with newly registered firms and well-established firms. She assists firms with developing and maintaining a robust compliance program through guidance of policies and procedures, risk assessments, and performing day-to-day compliance duties. [mailto:sara.sparks@truewest-consulting.com](mailto:sara.sparks@truewest-consulting.com) ![Tammy\_Headshot-min](https://blog.truewest-consulting.com/hs-fs/hubfs/Website%20Imagery/Headshots/Tammy_Headshot-min.jpg?width=225&height=225&name=Tammy_Headshot-min.jpg) ## Tammy Steffen Associate As a Compliance Consultant/Associate with True West Consulting, Tammy brings 39 years of experience throughout the financial services industry. With extensive experience in compliance procedures and policies, operations, and supervision, Tammy has worked with Broker-Dealer, and Registered Advisory firms to bolster and enhance their operations and compliance programs. [mailto:tammy.steffen@truewest-consulting.com](mailto:tammy.steffen@truewest-consulting.com) ![HughSimpson\_Headshot-2-min](https://blog.truewest-consulting.com/hs-fs/hubfs/Website%20Imagery/Headshots/HughSimpson_Headshot-2-min.jpg?width=225&height=225&name=HughSimpson_Headshot-2-min.jpg) ## Hugh Simpson Consultant Hugh Simpson is a skilled professional in the financial services industry, with a deep background in the areas of legal, compliance, internal audit, enterprise risk management, corporate governance and government relations. He recently completed a 33-year stint as Executive Vice President – General Counsel and Corporate Secretary of two significant Fort Worth-based financial services companies. Prior to that he was a partner in the Corporate and Securities Section of one of the oldest and largest law firms in Fort Worth. Hugh now consults on a variety of issues in the financial services space. He takes a sensible, solutions-oriented approach to risk management, promotes effective corporate governance, and upholds high ethical standards. [mailto:contact@truewest-consulting.com](mailto:contact@truewest-consulting.com) ![Aaron Payne - Headshot](https://blog.truewest-consulting.com/hs-fs/hubfs/Aaron%20Payne%20-%20Headshot.jpg?width=1575&height=1575&name=Aaron%20Payne%20-%20Headshot.jpg) ## Aaron Payne Consultant **Aaron Payne** is an IT Infrastructure and Cybersecurity specialist with deep experience leading technology transformation efforts within the financial services sector. In recent years, he has helped RIAs and FMOs modernize disjointed and outdated IT environments - bringing them into alignment with regulatory expectations and operational best practices. His work focuses on building secure, well-governed systems that support business growth, reduce risk, and hold up under regulatory and audit scrutiny. [mailto:deshaunne.kurulak@truewest-consulting.com](mailto:deshaunne.kurulak@truewest-consulting.com) ![David Lewien](https://blog.truewest-consulting.com/hs-fs/hubfs/David%20Lewien.jpg?width=1575&height=1575&name=David%20Lewien.jpg) ## David Lewien CEO - Go West IT David Lewien is the founder and CEO of Go West IT in Greenwood Village, Colorado. Founded in 2010, Go West IT is the security obsessed Managed Service Provider that expertly guides businesses to opportunity and protects them from harm in the digital frontier. [mailto:david.lewein@truewest-consulting.com](mailto:david.lewein@truewest-consulting.com) ![Mark Brown](https://blog.truewest-consulting.com/hs-fs/hubfs/Mark%20Brown.jpg?width=1575&height=1575&name=Mark%20Brown.jpg) ## Mark Brown Founder - Advisor Armor Mark Brown is the founder of Advisor Armor [mailto:deshaunne.kurulak@truewest-consulting.com](mailto:deshaunne.kurulak@truewest-consulting.com) ![Bridget-Katz](https://blog.truewest-consulting.com/hs-fs/hubfs/Website%20Imagery/Headshots/Bridget-Katz.jpeg?width=2400&height=2400&name=Bridget-Katz.jpeg) ## Bridget Katz  Project Manager and Onboarding Associate  As a Project Manager and Onboarding Associate with True West, Bridgetbrings over 20 years of extensive experience in the financial industry, specializing in serving large RIAs and their high-net-worth clients. In addition to serving RIAs, she led the onboarding advisor experience for a TAMP, demonstrating her expertise in streamlining client and advisor onboarding processes. Passionate about delivering end-to-end onboarding solutions, Bridget has successfully managed onboarding for multiple RIAs, supporting hundreds of users by ensuring seamless system access, compliance, and comprehensive training. Additionally, she has overseen client service operations, optimized systems, and aligned departmental efforts to ensure every client interaction reflects the highest standards of service. [mailto:bridget.katz@truewest-consulting.com](mailto:bridget.katz@truewest-consulting.com) ![Anna-Burdine](https://blog.truewest-consulting.com/hs-fs/hubfs/Website%20Imagery/Headshots/Anna-Burdine.jpeg?width=2400&height=2400&name=Anna-Burdine.jpeg) ## Anna Burdine Associate Anna is a Compliance Associate at True West Consulting with five years of compliance experience. She is an accomplished financial services professional with a strong background in compliance, supervision, and advisor support on the broker dealer side of business. Prior to her current role, she worked at LPL Financial as a supervisory principal on the advisor review team where she held her Series 7 and 24 licenses. Now with True West, she is excited to draw on her broad industry expertise as she transitions to supporting RIAs. 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