Which security rule usually applies, by type of firm
| Type of firm | Main rule to check | What it requires of IT |
|---|---|---|
| Mortgage brokers and lenders, finance companies, tax preparers | FTC Safeguards Rule (16 CFR 314) | Qualified Individual, MFA, encryption, testing, vendor oversight, 30-day FTC breach notice |
| SEC-registered investment advisers, broker-dealers, funds | SEC Regulation S-P, as amended in 2024 | Written incident response program, vendor oversight, 72-hour notice from vendors, 30-day customer notice |
| Firms regulated by New York DFS | 23 NYCRR Part 500 | MFA for all users, asset inventory, 72-hour notice to DFS, annual certification by April 15 |
| Banks and credit unions | Their own federal or state banking regulator, not the FTC | Follow your examiner's expectations; confirm with your compliance team |
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Get a quote for my firmBreach notice deadlines and attorney general rules for all 50 states and DC are in our state data breach notification law table.
- IT services for financial firms
- IT services for financial firms are outsourced technology and security support for banks, credit unions, advisers, funds, lenders and insurance agencies that covers day-to-day IT plus the written security program, testing, vendor oversight and incident response that financial privacy and cybersecurity rules require.
What IT services for banks and financial firms include
Financial firms buy the same help desk, device and network support as any office, plus a documented security program that a regulator, an examiner or an institutional client can inspect. The documentation is often as much work as the technology.
Common scope for IT support for banks, credit unions, advisers and lenders:
- Help desk and device management, including secure remote access.
- MFA, endpoint detection and response, email security and encryption.
- Logging and monitoring, with retention long enough for an investigation.
- Vulnerability scanning and penetration testing on a set schedule.
- Backup and recovery, with documented recovery time objectives.
- Policies, an asset inventory, a risk assessment and an incident response plan.
- Evidence packages for exams, audits and client due diligence questionnaires.
Day-to-day managed IT falls in a typical published range of $100 to $250 per user per month, and plans that include more security tooling reach $300 or more 34. Compliance-specific work is often priced separately: a small external penetration test typically starts around $5,000 9, and a virtual CISO to lead the program runs about $1,500 to $4,000 a month for firms under 50 employees in published pricing 10. Our managed IT pricing guide and vCISO services guide break these down.
GLBA and the FTC Safeguards Rule for mortgage companies and lenders
The FTC Safeguards Rule implements the Gramm-Leach-Bliley Act for financial institutions that are not under another regulator's enforcement authority, which in practice means non-bank firms 7. The FTC's examples include mortgage lenders, mortgage brokers, payday lenders, finance companies and tax preparation firms 8.
The rule's main technical requirements:
- A Qualified Individual who oversees the program; this can be an employee or a service provider 7.
- A written risk assessment 7.
- Encryption of customer information in transit and at rest 7.
- Multi-factor authentication on every information system, for every user 7.
- Continuous monitoring, or annual penetration testing plus vulnerability assessments every six months 7.
- A written incident response plan and an annual written report to the board 7.
- FTC notice within 30 days of discovering unauthorized acquisition of unencrypted information about 500 or more consumers, in effect since May 13, 2024 7.
Firms holding information on fewer than 5,000 consumers are exempt from four of these provisions but still need MFA and encryption 7. Banks and credit unions follow their own federal or state regulators rather than the FTC rule 7; their IT providers should be ready to work to examiner expectations. Title companies and insurance agencies should confirm with counsel which regulator and rule covers them.
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Get a quote for my firmSEC Regulation S-P for advisers, hedge funds and private equity
SEC Regulation S-P now requires covered firms to run a written incident response program, oversee their service providers and notify affected customers of a breach. The SEC adopted the amendments on May 16, 2024; they were published June 3, 2024 and took effect August 2, 2024 2. Larger entities had 18 months and smaller entities 24 months to comply 1, which put the compliance dates at December 3, 2025 and June 3, 2026. Both have passed.
Covered institutions include broker-dealers, investment companies, SEC-registered investment advisers and transfer agents, which reaches many wealth management firms, hedge fund managers and private equity advisers 1. Confirm your own status with counsel.
What the amendments mean for IT:
- Notify customers whose sensitive information was, or is reasonably likely to have been, accessed without authorization, no later than 30 days after becoming aware 2.
- Get 72-hour notice from vendors. Service providers must notify the firm no later than 72 hours after becoming aware of a breach 2. That belongs in your IT provider's contract.
- Detect and investigate. You cannot assess what was accessed without logs, so log retention and monitoring move from nice to have to necessary.
Funds and private equity firms also field security questionnaires from limited partners. A program built for Reg S-P answers most of them.
NYDFS Part 500 for New York financial firms
Firms regulated by the New York State Department of Financial Services must meet 23 NYCRR Part 500, and the final phase of its Second Amendment arrived on November 1, 2025 5. If your firm holds a DFS license or charter, check with counsel whether you are a covered entity.
Requirements with the biggest IT impact:
- MFA for any individual accessing any information system since November 1, 2025, unless the CISO approves a compensating control 6.
- A complete, documented asset inventory that tracks owner, location, sensitivity, support end date and recovery time objective 5.
- Notice to DFS no later than 72 hours after determining a cybersecurity incident occurred 5.
- Annual certification of material compliance, or acknowledgment of noncompliance, by April 15 5.
Smaller firms may qualify for the 500.19(a) limited exemption: fewer than 20 employees and contractors, or less than $7,500,000 in gross annual revenue in each of the last three fiscal years, or less than $15,000,000 in year-end total assets 5. The exemption removes several sections but not all. Exempt firms still need MFA for remote access, for third-party applications holding nonpublic information, and for privileged accounts 6.
Vendor due diligence for financial firms
Every rule on this page holds the firm responsible for its vendors, and your IT provider is usually the vendor with the most access. The FTC rule requires overseeing service providers 8, Reg S-P requires 72-hour breach notice from them 2, and the 2026 Verizon DBIR found third-party involvement in 48% of breaches 11.
Ask any IT provider for:
- A description of its own security controls, including MFA on its remote management tools and how its technicians' accounts are protected.
- Contract terms for breach notice (72 hours or less), cooperation in investigations and return of data at the end of the contract.
- The list of subcontractors that will touch your systems or data.
- Evidence it can produce for you: patch reports, backup test results, access reviews.
- Willingness to sit in on an exam or answer an auditor's questions.
Apply the same review to your custodian, CRM, portfolio and loan origination platforms. Our guide to choosing an MSP lists general contract questions, and managed security services explains the monitoring side.
Cybersecurity for financial advisors, credit unions and insurance agencies
Small financial firms face the same attacks as large ones, aimed at money movement. The FBI recorded about $3.05 billion in business email compromise losses in 2025 12, and fraudulent requests to move client funds or change bank details are the common thread.
A workable order for a firm of 5 to 50 people:
- MFA on every account, starting with email, custodian and banking portals. Microsoft research found MFA reduces account compromise risk by 99.22% 13.
- Callback verification for any change to payment or wiring instructions.
- EDR on every device, then managed detection and response so alerts are watched at night. A 2026 market analysis put mainstream MDR at $8 to $25 per endpoint per month 14.
- Encrypted, tested backups.
- A written incident response plan that names who calls the regulator, the insurer and the FBI.
Hiring in-house is costly at this size: the median information security analyst earned $129,180 in May 2025 15, before benefits. For a broader small-firm plan see cybersecurity for small business. Tax practices should read our accounting firm IT page; for the rules in each sector side by side, see the industries overview.
Common questions
What cybersecurity rules apply to financial advisors?
SEC-registered investment advisers are covered by Regulation S-P, which since the 2024 amendments requires a written incident response program, service provider oversight and customer notice within 30 days of a breach 2. Advisers regulated by New York DFS may also fall under 23 NYCRR Part 500 5. Confirm your status with counsel.
When did the Regulation S-P amendments take effect?
Does the FTC Safeguards Rule apply to mortgage companies?
What IT services do banks and credit unions need?
Banks and credit unions need managed IT plus documented security controls, testing and vendor oversight that satisfy their federal or state examiners, which differ from the FTC rule 7. Ask any provider whether it has supported a bank or credit union through an exam before.
How much do IT services for hedge funds and private equity firms cost?
Are small New York financial firms exempt from NYDFS Part 500?
Partly. Firms under 20 employees and contractors, under $7.5 million in revenue in each of the last three years, or under $15 million in year-end assets qualify for a limited exemption 5. They still need MFA for remote access and privileged accounts, a risk assessment, an asset inventory and annual certification.
What should insurance agencies look for in IT support?
Strong email security and MFA, encrypted storage of customer data, tested backups and a provider that will sign contract terms on breach notice. Agencies licensed by New York DFS should also check Part 500, including its 72-hour notice requirement 5.
Sources
- U.S. Securities and Exchange Commission, SEC Adopts Amendments to Regulation S-P to Enhance Protection of Customer Information (press release 2024-58), 2024-05-16.
- Federal Register (SEC), Regulation S-P: Privacy of Consumer Financial Information and Safeguarding Customer Information, 2024-06-03.
- Flamingo, Cost of IT Support for Small Business, 2026-04-08.
- Strategic Micro Systems, Managed IT Services Cost Per User: A 2026 Pricing Guide, 2026-05-20.
- New York State Department of Financial Services, 23 NYCRR Part 500 (Cybersecurity Requirements for Financial Services Companies), 2026.
- New York State Department of Financial Services, New York MFA Requirements, 2026.
- eCFR, 16 CFR Part 314: Standards for Safeguarding Customer Information, 2026-10-08.
- Federal Trade Commission, FTC Safeguards Rule: What Your Business Needs to Know, 2024-12.
- Compass IT Compliance, How Much Does Penetration Testing Cost In 2026? Full Transparency, 2025-06-03.
- SideChannel, vCISO Pricing in 2026: What You'll Actually Pay, 2026-10-02.
- Center for Internet Security, CIS Controls and MS-ISAC Insights Featured in Verizon's 2026 Data Breach Investigations Report, 2026-05-19.
- FBI Internet Crime Complaint Center, 2025 IC3 Annual Report (Internet Crime Report 2025), 2026.
- Microsoft (Meyer et al.), arXiv, How effective is multifactor authentication at deterring cyberattacks?, 2023-05-01.
- BD Emerson, SOC as a Service Pricing: What Drives the Number, 2026-07-18.
- U.S. Bureau of Labor Statistics, Occupational Outlook Handbook: Information Security Analysts, 2026.
Updated October 13, 2026.