Request for Extension of the Compliance Date for Amendments to Regulation S-P (Joint Trades)

Summary

SIFMA, SIFMA AMG, American Bankers Association (ABA), Bank Policy Institute (BPI), Committee of Annuity Insurers (CAI), Financial Services Institute (FSI), Institute of International Bankers (IIB), Investment Adviser Association (IAA), Investment Company Institute (ICI), and the Insured Retirement Institute (IRI), provided comments to the U.S. Securities and Exchange Commission (SEC) requesting to extend the compliance deadlines for the Regulation S-P amendments (“Regulation S-P Amendments) for larger and smaller entities by an additional six months each.

Excerpt

November 19, 2025

By Electronic Submission

The Hon. Paul Atkins
Chairman
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-1090

Re: Request for Extension of the Compliance Date for Amendments to Regulation S-P: Privacy of Consumer Financial Information and Safeguarding Customer Information (File No. S7-05-23)

Dear Chairman Atkins,

The American Bankers Association (“ABA”), Bank Policy Institute (“BPI”), Committee of Annuity Insurers (“CAI”), Financial Services Institute (“FSI”), Institute of International Bankers (“IIB”), Insured Retirement Institute (“IRI”), Investment Adviser Association (“IAA”), Investment Company Institute (“ICI”), Securities Industry and Financial Markets Association (“SIFMA”), and SIFMA Asset Management Group (“SIFMA AMG”), (collectively, the “associations”) respectfully request that the Securities and Exchange Commission (the
“Commission” or “SEC”) extend the compliance deadlines for the Regulation S-P amendments (“Regulation S-P Amendments) ¹ for larger and smaller entities by an additional six months each. If granted, the revised compliance dates would be June 3, 2026, for larger firms and December 3 2026, for smaller firms.

The associations and their members remain committed to fully implementing the Regulation S-P Amendments by the applicable deadlines if necessary. Our request is not to delay compliance unnecessarily, but to ensure that firms can fully operationalize the Regulation S-P Amendments in a way that is sound, scalable, and aligned with the Commission’s expectations. Our members respectfully submit that a modest extension is reasonable, prudent, and necessary given the cumulative impact of the unprecedented 43-day shutdown and the absence of guidance during certain implementation windows.

As the Commission is aware, the associations previously requested an extension of the compliance dates on April 25, 2025, due to the significant operational and technological work required to implement the amended requirements. ² In July, some of the associations also provided detailed suggested modifications to the Regulation S-P Amendments to further emphasize the challenges that firms face with complying with the amendments as written and, as an alternative to reopening the rule, the IAA requested certain clarifications and refinements.

The associations have not received a response from the Commission or staff on the prior extension request or the proposed modifications, clarifications, and refinements. ³ To assist the staff in developing guidance, SIFMA and the IAA also submitted proposed FAQs to the Division of Trading & Markets and the Division of Investment Management in September 2025, but have not received a response to those requests to date.

The associations acknowledge that the Commission held its first compliance outreach
webinar for larger firms on September 25, 2025. Notably, the feedback from the associations’
members was that the guidance provided during that session, while appreciated, was high-level and summary in nature. Moreover, many questions raised by our members during the webinar were not expressly answered.

An additional six months would give the Commission the necessary time to consider these recommendations and work with the associations to find solutions to the challenges presented. The associations believe the 43-day government shutdown has significantly delayed the Commission staff’s ability to review and sufficiently consider the associations’ requests for an extension, the additional suggested amendments, clarifications, refinements, and the suggested FAQ guidance. The lack of additional interpretive guidance and practical clarity on several core provisions of the Regulation S-P Amendments – including the application of these requirements to service providers – may lead to inconsistent interpretations. Many of the Regulation S-P Amendments impose substantial, enterprise-wide changes that require coordination across legal, compliance, cybersecurity, technology, and third-party risk management teams. Without essential staff engagement or clarification of ambiguous requirements, firms risk building programs that may not align with the Commission’s intended expectations.

Finally, we note that the Division of Examinations recently highlighted Regulation S-P
compliance in its priorities for 2026. ⁴ Providing firms additional time to receive interpretive guidance from the Commission staff will greatly improve the data that the Commission receives during the examination process next year and ensure that registrants and the staff have a shared understanding of expectations before the examinations begin.

We appreciate the Commission’s consideration of this request and stand ready to engage further at your convenience. Please reach out to Melissa MacGregor at mmacgregor@sifma.org with any questions or to set up a meeting with the associations.

Sincerely,

American Bankers Association
Bank Policy Institute
Committee of Annuity Insurers
Financial Services Institute
Institute of International Bankers
Investment Adviser Association
Investment Company Institute
Insured Retirement Institute
Securities Industry and Financial Markets Association
SIFMA Asset Management Group

Cc: The Hon. Hester M. Peirce, Commissioner
The Hon. Caroline A. Crenshaw, Commissioner
The Hon. Mark T. Uyeda, Commissioner
Vanessa Countryman, Secretary
Brian Daley, Director, Division of Investment Management
Jamie Selway, Director, Division of Trading and Markets

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