Picture this: a team member clicks a phishing email. Suddenly, your CRM data might be compromised. What do you do next?
If you don’t have a written incident response plan (IRP), you’re already behind.
What is an IRP?
Under the new Reg S-P amendments, RIAs are required to have a documented game plan for handling unauthorized access to client data. It’s not just about cleaning up the mess—it’s about showing regulators you were ready.
A good IRP includes:
- Clear roles and responsibilities
- Investigation steps
- Containment and eradication procedures
- Communication plans (internal and external)
- Customer notification guidelines
The Three Critical Steps
- Investigate: Determine what happened, which systems were affected, and whether client data was compromised.
- Contain: Stop the bleeding. Lock down affected systems and accounts.
- Notify: If harm is possible, notify affected clients within 30 days.
Why This Matters for SEC Compliance
Regulators want evidence that your firm acted swiftly and responsibly. That starts with having a written, up-to-date plan that’s easy to follow under pressure.
This isn’t just a checklist—it’s proof you take client data seriously.
Tips for Building Your IRP
- List All Critical Systems and Data – Know where your client data lives.
- Create an Escalation Matrix – Who gets called first? Who has decision-making authority?
- Run Tabletop Exercises – Simulate a breach so your team knows their roles.
- Integrate With Your MSP – Make sure your IT provider knows your plan and their role in it.
Peace of Mind Starts with Preparation
Having an IRP isn’t just a checkbox—it’s your safety net. And when things go wrong, it’s the difference between chaos and calm.
Need help building one? That’s where we come in.
