What the primary record establishes

The amended Regulation S-P requires covered firms to maintain written incident-response procedures. Where customer notice is required, it must be given as soon as practicable and generally within 30 days of awareness that unauthorized access or use occurred or was reasonably likely. SEC Regulation S-P amendments ↗ SEC final rule 34-100155 ↗

What the distinction changes

A CRM vendor may alert a broker on Monday and deliver a detailed report on Friday. Record what the firm knew on each date. The start of the clock turns on the information available, which may arrive before the investigation is complete.

What to check before drawing a conclusion

The rule addresses individuals whose sensitive information was or was reasonably likely to have been affected and includes limited exceptions. The notice describes the incident, data involved and protective steps. Track the vendor alert, recipient assessment and actual notices separately.