Financial services · SEC Reg S-P & GLBA
The amended Regulation S-P requires an incident response program with procedures to detect, respond to and recover from unauthorized access to customer information. The GLBA Safeguards Rule assumes something in the environment is monitoring. Both are written as capabilities, and both are routinely answered with a binder.
The gap
Reg S-P sets a 30-day customer notification obligation once you become aware that sensitive customer information was, or was reasonably likely to have been, accessed. Awareness is the trigger, and awareness depends on somebody reading the alerts.
A twelve-person RIA has a Microsoft tenant, an MSP, an endpoint agent and a compliance consultant. It does not have an analyst, and it will not be hiring one to satisfy a rule.
"We monitor" invites the follow-up question. What holds up in an exam is a dated log of activity being reviewed, decisions being made, and escalations being handled, with names and timestamps.
The mechanism
Every alert your stack produces is reviewed and dispositioned with written reasoning. Anything that looks like unauthorized access to customer information escalates to a human with an investigation record attached, which is precisely the artifact the notification decision has to be based on.
The compliance evidence is not a separate workstream. It is what is left behind by the detection and response program actually running.
| Obligation | What Intruex performs |
|---|---|
| Reg S-P: incident response program detect, respond, recover | Continuous alert review, escalation packages, approval-gated response |
| Reg S-P: notification determination | Investigation record per escalation: what was checked, what was found, what was concluded |
| GLBA Safeguards: monitoring & testing | Every alert triaged and dated, with coverage visible rather than asserted |
| GLBA Safeguards: incident response plan | A documented, exercised path from alert to decision to action |
Intruex is a security operations platform, not legal or compliance counsel. Control mapping shows where our activity supports an obligation; your program still owns the determination.
If you have no SOC
For smaller advisers and firms we build the detection layer first, as an engagement, and then run the platform on top of it, so you get an operating capability rather than a tool that needs one to already exist.
Vendors whose pricing starts in the tens of thousands per year for a fixed investigation count cannot serve this end of the market. We are built for it.
Data residency
Alert metadata can carry account identifiers. Your vendor risk assessment has to account for where it is processed.
Hand it something from last week and read the reasoning. If the verdict is wrong, you will see exactly where it went wrong, which is the whole point.
