A practical path to a Reg S-P–ready Incident Response Program specifically tailored to your environment — built for the CCO responsible for compliance, Vendor Due Diligence, exam prep, and client issues all at the same time.
About an hour of your time — not 40 hours.
We handle discovery, drafting, and delivery. You finish comfortably before the June 3 deadline. A typical engagement runs four to six weeks from first call to final deliverables and training.
Easy to implement. Tailored to your firm. No guesswork if an incident hits.
You give us about an hour. We do the rest. Complete our Business Practices Questionnaire at your convenience — and if we have follow-up questions or open items, a short call closes them out. From there, we handle discovery, drafting, and every deliverable. Four to six weeks from first call to finished program.
Every runbook, vendor entry, and scope filter reflects your actual environment — your custodians, your IT provider, your staff and devices. No generic playbook mentioning systems you don't have.
The Tech Lead Worksheet walks IT through containment step by step. The IRL Command Guide covers first-24-hour decisions. The IR Scope Matrix filters every device and app in seconds.
The engagement is structured around a single principle: the CCO's time is the scarce resource.
Across dozens of engagements we see similar patterns at firms your size. For most CCOs, reading this list is the first time the situation gets described clearly — which, by itself, makes the path forward a lot less overwhelming.
Many small RIAs can't produce a system-by-system inventory on request. Shadow IT is nearly universal — cloud tools adopted by individual advisers, rarely documented, forgotten until an incident forces the question.
Custodians and major platforms are usually fine. A consequential gap is often the local IT provider — domain admin, remote access to every workstation, no SOC report, and frequently no cyber liability insurance.
A template in a binder isn't a program. Few firms have firm-specific scenario runbooks, a designated Incident Response Lead with a documented command chain, or a tested intake and escalation process.
Most CCOs are familiar with the 30-day client notification window, but the mechanics are fuzzy: when does the clock actually start, what counts as "sensitive customer information," and who has authority to make the call. Under pressure, ambiguity becomes paralysis.
From the date the firm discovers a breach involving sensitive customer information, under Reg S-P §248.30.
Written agreements with service providers must require breach notification within 72 hours. The firm's VDD program is where this obligation lives.
Incident records and related documentation retained under Reg S-P and the firm's Books and Records obligations.
If this has been sitting on your desk for months, the hardest part is just scheduling the first call. After that, it's off your desk — so you can get back to the dozen other #1 priorities on your list.
Book a Meeting — NOW