Cyber incident advisory across regulated financial institutions

Advising financial institutions on the regulatory implications of cybersecurity incidents.

Cyber incidents within regulated financial institutions carry immediate regulatory and disclosure consequences. These matters are assessed not only based on the nature of the incident, but on how the firm identifies, escalates, documents, and discloses the event under applicable securities laws, SEC guidance, and supervisory frameworks.

RegComp advises investment advisers, private fund sponsors, broker-dealers, capital acquisition brokers, and related financial institutions on the regulatory implications of cybersecurity incidents. Our work focuses on how incidents and related response activities are evaluated in practice in examinations, regulatory inquiries, and enforcement contexts.

Our role is to assess the regulatory implications of the firm’s response to a cybersecurity incident and to guide the integration of that response within the firm’s compliance and supervisory framework. This includes evaluation of regulatory exposure, disclosure considerations, escalation practices, and documentation requirements. We coordinate with cybersecurity providers and external counsel, and advise on how the firm’s actions, communications, and internal records will be evaluated under applicable regulatory expectations.

We also assist in documenting the incident within the firm’s compliance program, including incident reporting, testing records, and policy and procedural updates, ensuring consistency across the firm’s regulatory framework.