In a recent speech, Acting Director of the SEC’s Division of Examinations (Exams) Keith Cassidy reminded SEC registrants of the new requirements imposed by the amendments to Regulation S-P. He noted that the dates for compliance are approaching and provided information about how Exams intends to proceed. The bottom line on compliance preparedness is that there is no better time than the present, particularly for larger entities and most broker-dealers, who have the earliest compliance date of Dec. 3, 2025. Smaller entities must comply with the amendments by June 3, 2026. Read on to learn what covered institutions should do to assess their readiness and prepare for the compliance date.

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Photo of David Hirsch David Hirsch

Dave is a highly respected member of the securities enforcement and regulatory counseling practice group at McGuireWoods, where he plays a key role shaping the strategic direction of the firm’s securities enforcement initiatives. Before joining McGuireWoods, Dave was Chief of the Crypto Assets…

Dave is a highly respected member of the securities enforcement and regulatory counseling practice group at McGuireWoods, where he plays a key role shaping the strategic direction of the firm’s securities enforcement initiatives. Before joining McGuireWoods, Dave was Chief of the Crypto Assets and Cyber Unit in the SEC Division of Enforcement, and prior to that served as enforcement counsel to SEC Commissioner Crenshaw. He is a recognized expert and frequent speaker with a robust practice that spans a wide array of complex regulatory and enforcement matters, particularly those involving crypto and cyber.

Photo of Tara Bradley Tara Bradley

Tara is a seasoned attorney who focuses on digital media, intellectual property, technology, procurement, entertainment, marketing and advertising transactions. With insight gained from years of experience as in-house counsel, Tara understands the dynamic and fast-paced business environment.

Photo of Nathanael Williams Nathanael Williams

Nate’s practice focuses on providing pragmatic, strategic, and business-minded privacy and data security counseling. Nate advises clients on compliance with state and federal privacy laws and regulations, emerging technology risks, preparing for and responding to data breaches, and privacy, data security, and technology-related…

Nate’s practice focuses on providing pragmatic, strategic, and business-minded privacy and data security counseling. Nate advises clients on compliance with state and federal privacy laws and regulations, emerging technology risks, preparing for and responding to data breaches, and privacy, data security, and technology-related risks in business mergers and acquisitions, as well as licensing, outsourcing, and commercial transactions.