Joint Follow-up Letter on Regulation S-P Amendments

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) 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. 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.

Download the joint comment letter to read the full text.