For SEC-registered investment advisers

A dated incident response program naming your actual systems, plus a service-provider file that is chased, logged and re-dated every month.

For $249 instead of a four-figure retainer.

Get the free printable log sheet

A one-page monthly log for your rooms: date, result, who checked and what was done. We email it straight over.

Northfile keeps it for you every month for $249/month.

Get started, $249.00/month See a sample deliverable

The date already passed

Amended Regulation S-P has applied to smaller advisers since 3 June 2026. If your firm still has no written incident response program, you are already past the date, and the service-provider side is the part you cannot finish in a weekend, because it depends on other people answering.

Hand an SEC examiner a dated written incident response program built around the firm's real systems, and a service-provider file showing what each vendor has committed to on breach notice, who was written to where nothing was committed, and what came back - without a $667-$1,500 a month retainer.

What you get

Regulation S-P Incident Response Program and Service-Provider Evidence File.

Month 1

The program and the register, built

A written incident response program naming the firm's actual custodian, CRM, portfolio software and email archive, with the assess/contain/notify procedures the rule calls for; the customer-notification letter set and a 30-day notification playbook; and a service-provider register built from the firm's vendor list that records, for each vendor, the breach-notification commitment it already publishes (contract or data-processing terms, trust-centre page, SOC 2 availability) and flags the ones with none.

Every month after

The flagged vendors, chased and logged

A written request sent on the firm's behalf to each flagged vendor asking for a 72-hour breach-notice commitment, the reply or the silence logged with its date, new vendors added, the register and program re-dated, and a one-page evidence memo for the file.

Annually

A review and a refreshed program

A review memo and a refreshed program. Delivered as PDFs and an editable file the CCO adopts and signs.

A sample page from the file

An excerpt from a service-provider register, with vendor names redacted. Your copy names your actual vendors.

Pricing

$249.00/month

One program. One register. Chased and re-dated every month.

Get started, $249.00/month

Included

This covers the incident response program, the notification set and the service-provider file.

Not included

It does not cover your disposal procedures, your annual privacy notice or the rest of your compliance manual.

What we cannot do is make a custodian or a software vendor sign anything - no one can - so we promise the request, the log and the dated file, not the vendor's answer. We are not a law firm and we do not give legal advice: your CCO reviews, adopts and signs everything.

Questions

This covers the incident response program, the notification set and the service-provider file. It does not cover your disposal procedures, your annual privacy notice or the rest of your compliance manual.

Amended Regulation S-P has applied to smaller advisers since 3 June 2026.

Requests we send to your service providers on your behalf may go unanswered. We log the outcome as it happens and cannot compel any provider to respond or agree. No examination outcome is promised.

We are not a law firm and we do not give legal advice: your CCO reviews, adopts and signs everything.

The principal or chief compliance officer of a 1-10 person SEC-registered investment adviser with no full-time compliance staff.

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30-day money-back guarantee. Questions? Email claude@dansventures.com.