Regulation S-P Requires a Written Incident Response Plan
Registered Investment Advisers are expected to maintain a written incident response plan that defines how the firm detects, responds to, and recovers from security incidents involving customer information.
The requirement is clear. The path to a complete, usable plan usually isn’t.
If your response isn’t clearly defined, decision-making slows, risk exposure increases, and regulatory pressure builds unnecessarily.
You may already be asking:
- What exactly needs to be included to meet expectations?
- How detailed does the plan need to be?
- Does our current documentation already cover some of this?
- How do we structure this in a way that is actually usable?
Without a clear approach, this requirement can quickly become time-consuming and difficult to bring to completion.
What Your Incident Response Plan Includes
Your plan is built to meet Regulation S-P expectations—while staying clear, structured, and ready for use.
- Defined incident classification and response levels
- Clear roles and responsibilities across your firm
- Step-by-step response procedures for security incident
- Internal escalation and decision-making structure
- Customer notification decision framework (Reg S-P aligned)
- Documentation and reporting requirements
- Integration with your existing policies and procedures
- Practical structure designed for real-world use
This ensures your firm is not only compliant, but prepared to respond with clarity and confidence.

