> For the complete documentation index, see [llms.txt](https://policies.fundapps.co/client-portal/-LubIC9uIsME-_T0mNXu/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://policies.fundapps.co/client-portal/-LubIC9uIsME-_T0mNXu/legal-information/laws-and-regulations/sec-regulation-s-p-amendments-may-2024.md).

# SEC Regulation S-P Amendments (May 2024)

### **Summary**

In May 2024, the U.S. Securities and Exchange Commission (SEC) adopted amendments to Regulation S-P: Privacy of Consumer Financial Information and Safeguarding Customer Information. These changes enhance data protection obligations for certain regulated financial institutions and their service providers.

<mark style="color:$success;">FundApps position:</mark> The amendments do not impact FundApps obligations under Regulation S-P, as FundApps does not process or store any “Customer Information” as defined by the rule and therefore no change to FundApps regulatory obligations or customer data handling practices is required.

***

### **Overview of Regulation S-P**

Regulation S-P sets out privacy and safeguarding standards for specific U.S. financial institutions, including:

* Registered investment advisers
* Broker-dealers
* Investment companies
* Transfer agents

The regulation governs the protection of non-public personal information (NPI) belonging to consumers and customers of these institutions.

***

### **Key 2024 Amendments**

The SEC’s May 2024 amendments aim to modernize Regulation S-P and strengthen data protection obligations. Key updates include:

* **New Defined Term – “Customer Information”**\
  Replaces “Customer Records and Information” to clarify the scope of protected data.\
  Refers to any record containing non-public personal information about a customer of a financial institution, whether held directly by the institution or by a service provider on its behalf.
* **Expanded Safeguarding Obligations**\
  Covered institutions must establish and maintain written policies and procedures to protect and dispose of customer information securely.
* **Service Provider Oversight**\
  Financial institutions must ensure that service providers with access to customer information maintain appropriate safeguards and disposal controls.

***

### **Why FundApps Is Not Impacted**

The 2024 amendments to Regulation S-P do not apply to FundApps for the following reasons:

* FundApps is not a “financial institution” under Regulation S-P, but a service provider.
* FundApps does not process or store “Customer Information” as defined in the amended rule.
* Information provided by FundApps clients is limited to employee names and emails (i.e. login credentials) for access control, which does not constitute “consumer financial information” or “customer data” under Regulation S-P.

Accordingly, FundApps role and data handling practices remain outside the scope of the rule’s privacy, safeguarding, and disposal obligations.


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