Understanding the New Reg. S-P Requirements: Incident Response and Vendor Oversight Requirements for Wealth Managers
- Scope of the rule: which advisers and what information is covered?
- Developing policies to comply with the new rule
- Breach notification requirements – timing and coordination
- Service provider oversight – due diligence, monitoring, and reporting incidents
- Recordkeeping requirements
- Timing and contents of the breach notice
- Upcoming compliance deadlines
Speakers
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E.J. YerzakManaging Director, Salus GRCE.J. Yerzak, CISA, CISM, CRISC, is Managing Director at Salus GRC. He has over two decades of experience as a cybersecurity and regulatory compliance professional and thought leader helping financial services firms manage risk. His cybersecurity experience includes governance, vulnerability and penetration testing, consulting on data security incidents, reporting frameworks and related cybersecurity risk assessments (including NIST and NYDFS), and vendor due diligence, as well as management of teams conducting phishing testing and dark web monitoring. His regulatory experience includes consulting for private equity funds, hedge funds, pension consulting firms, and retail wealth managers on investment adviser compliance programs, compliance forensic testing, risk assessments, and annual reviews.
Prior to joining Salus GRC, E.J. was Director of Cybersecurity Services for Confluence Technologies, which acquired Compliance Solutions Strategies (CSS) where he served in the same role. CSS acquired Ascendant Compliance Management, where E.J. was a Partner and senior consultant.
As a cybersecurity expert, E.J. has authored numerous articles on emerging technology and regulatory issues published in journals and by third parties and is the author of two award-winning technothriller fiction novels. He is frequently requested to speak at industry conferences around the world on cybersecurity, regulatory compliance, and blockchain.
E.J. holds a juris doctorate (J.D.) magna cum laude from Quinnipiac University School of Law and is licensed to practice at the State Bar of Connecticut and in federal court before the District Court for the District of Connecticut. He also has an MS from Central Connecticut State University in Computer Information Technology/Computer Science, and a dual BA from Colgate University magna cum laude in English and Computer Science.
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Salvatore PapaChief Legal & Risk Officer, Buckingham Strategic WealthSal serves as the Chief Legal & Risk Officer (CLRO) for The Colony Group / Buckingham. Sal joined The Colony Group through the recent merger of Buckingham Strategic Wealth and The Colony Group. In his role as CLRO, Sal is responsible for overseeing legal, compliance, and risk management functions. Prior to joining The Colony Group, he was on the Board of Directors of Buckingham Wealth Partners and served as the General Counsel and Chief Compliance Officer. He also previously served as the Chief Compliance Officer for the SA Funds. Sal has worked in the investment adviser industry for 20 years. Prior to joining Buckingham in 2015, he was a Partner and Board Member at a national regulatory consulting firm.
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Christopher MendezSenior Counsel, Crowell & MoringChristopher Mendez is a senior counsel in the New York office of Crowell & Moring. Chris is an experienced alternative investment attorney whose expertise spans the broader investment management industry, including advising on complex fund formation and transactional matters, as well as SEC examination and enforcement experience.
Chris has significant experience in the structuring and formation of a wide array of investment funds and other pooled investment vehicles, including hedge funds, credit funds, hybrid funds, private equity funds, real estate funds, digital asset funds, venture funds, single investor funds, co-investments, joint ventures, and separately managed accounts. In addition to fund formation, Chris has experience in corporate and fund-related transactions, including, seeding arrangements, spinouts, lift-outs, investment management, M&A, and new financial product development.
With his deep understanding of front-, middle-, and back-office issues, Chris has managed legal and compliance teams across numerous asset classes and fund structures and regularly advises and represents fund managers on legal, compliance, and operational matters.
Prior to joining Crowell, Chris served as the General Counsel and Chief Compliance Officer of an investment fund and firm client, Commonwealth Asset Management (a spin-out of Soros Fund Management). He joined Commonwealth from Semper Capital Management, a credit-focused manager, where he was also General Counsel and Chief Compliance Officer.