The Securities and Exchange Commission’s (SEC) 2024 amendments to Regulation S-P are now fully in effect, with both compliance deadlines now behind us. For broker-dealers, investment advisers, private fund managers, and other covered institutions that worked hard to prepare incident response programs and other items necessary to meet their respective implementation deadlines, there’s no rest for the weary. Covered institutions should expect the SEC’s Division of Examinations to focus on whether firms have actually put their Reg S-P obligations into practice. According to the SEC’s Division of Examinations (Division) Fiscal Year 2026 Examination Priorities, the Division will examine whether firms have developed, implemented, and maintained policies and procedures in accordance with the rule’s new provisions that address administrative, technical, and physical safeguards for the protection of customer information. Now is the time for firms to assess their operational resiliency and the effectiveness of their programs in practice, not just on paper.