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The IT side of your compliance program, built for your CCO and SEC exams

Registered Investment Advisors IT Services

For a registered investment adviser, cybersecurity is a compliance obligation with a paper trail: the amended Regulation S-P expects a written incident response program and service provider oversight, Rule 204-2 expects your communications preserved, and exam staff expect proof that your policies match what really happens.

SOC 2 Aligned
Responsive Support
20+ Years Experience

At a glance

Most smaller RIAs have strong policies on paper and thin evidence behind them.

We run managed IT and cybersecurity for SEC- and state-registered advisers, working closely with your chief compliance officer.

That covers identity and device controls, email and messaging archiving, vendor oversight support, an incident response program that works in practice, and exam-ready evidence.

IT that keeps your CCO covered, records preserved, exams uneventful.

Managed IT for RIAs that need their cybersecurity policies to match what the systems actually do.

RIA IT & compliance

Your policies say it. Can your systems prove it?

Every RIA has a compliance manual with a cybersecurity section. Exam staff increasingly test whether reality matches it: who has access, which messages are archived, how vendors are overseen and what happens when something goes wrong. Here's where advisers get tripped up and what we put underneath the policies.

01 · The pressure

A compliance program that has to be real

Your CCO runs the annual review under Rule 206(4)-7, updates Form ADV and fields due diligence questionnaires from institutional clients. The amended Regulation S-P now requires a written incident response program, oversight of service providers that touch customer information and a process to notify affected clients. Advisors text, email and meet clients on video. Portfolio, CRM and custodian platforms hold everything. When exam staff request documents, your CCO needs evidence fast.

  • Annual review and Form ADV updates
  • Amended Reg S-P incident response duties
  • Exam document requests on short notice

02 · How it breaks

Off-channel texts and policies nobody tested

RIA problems are often gaps between policy and practice. Advisors text clients from personal phones, so business communications go unarchived, a pattern behind years of SEC off-channel enforcement. The incident response plan has never been exercised. Nobody can list which vendors hold client data. A phished advisor account sends clients a malicious link. And the IT provider can't produce access reviews or MFA reports when the CCO asks.

  • Client texts on personal phones, unarchived
  • Incident plans never tested
  • No list of vendors holding client data

03 · What we change

Archived channels, mapped vendors, a working plan

We route business email, Teams or Slack and approved texting through archiving that supports your Rule 204-2 obligations, and block or control channels you haven't approved. Every user gets phishing-resistant MFA and managed devices. We build a vendor inventory showing who holds customer information to support your Reg S-P service provider oversight. Then we write the technical incident response procedures with your CCO and rehearse them in a tabletop.

  • Archiving for email, chat and approved texting
  • Vendor inventory for Reg S-P oversight
  • Incident procedures rehearsed with your CCO

04 · The after

Exams where the evidence is already waiting

When an exam request letter arrives, your CCO pulls access reviews, MFA coverage, vendor inventory, archiving confirmation and the last tabletop report from one place. Institutional client questionnaires get answered accurately the same week. Advisors keep texting clients, through an approved and archived channel. And if an incident does happen, the team follows a plan they've practiced, with counsel making the notification calls.

  • Exam evidence kept current all year
  • Accurate answers on client questionnaires
  • A practiced plan when something happens

Systems we keep running

  • Orion
  • SS&C Black Diamond
  • Redtail CRM
  • Wealthbox
  • Smarsh
  • Schwab Advisor Center
  • Nitrogen

Rules we help you meet

  • SEC Regulation S-P (as amended 2024)
  • Advisers Act Rule 204-2 (books and records)
  • Advisers Act Rule 206(4)-7 (compliance programs)
  • SEC Regulation S-ID

What We Offer

Comprehensive solutions tailored for Houston-area businesses

Regulation S-P Program Support

The amended Regulation S-P requires a written incident response program to detect, respond to and recover from unauthorized access to customer information, oversight of service providers and customer notification procedures. We build the technical pieces with your CCO: detection, response playbooks, evidence preservation and the facts counsel needs to make notification decisions.

Communications Archiving

Rule 204-2 requires advisers to keep certain written communications, and off-channel messaging has drawn significant SEC enforcement. We configure archiving for email, Teams or Slack and an approved business texting solution, test that capture works and give your CCO search access for reviews and exam requests.

Vendor & Service Provider Inventory

Your custodians, portfolio management, CRM, planning, billing and archiving vendors all hold customer information. We maintain an inventory of each provider, what data it holds and how it connects, and collect security documentation like SOC reports, supporting the service provider oversight your compliance program now has to show.

Identity, MFA & Device Controls

We enforce phishing-resistant MFA across email, CRM, portfolio and custodian platforms, manage laptops and phones with encryption and endpoint detection and block access from unmanaged devices. Quarterly access reviews are produced as reports your CCO can file, so you can show who had access to what at any point.

Exam-Ready Evidence Package

We keep a living folder of the evidence exam staff typically request on cybersecurity: policies mapped to controls, access reviews, MFA coverage, patch reports, vendor inventory, backup tests, training records and incident logs. Updated on a schedule, it turns an exam request letter into a retrieval job instead of a project.

Tabletop Exercises & Response

An incident response program only works if people have practiced it. We run tabletop exercises with your principals and CCO around realistic scenarios like a phished advisor or a vendor breach, document the results for your annual review and respond during business hours, with after-hours emergency response for active incidents.

Why Choose LayerLogix?

Serving businesses throughout the Greater Houston area including Houston, Dallas, Austin, San Antonio, Atlanta, Nationwide.

Policies That Match Reality

Exam deficiencies often come from the gap between what the manual says and what the firm does. When your controls produce their own evidence, your CCO can show that the written program is actually in operation, which is exactly what exam staff look for.

Advisors Keep Their Workflow

Approved, archived texting and chat let advisors communicate the way clients prefer without creating a recordkeeping problem. You stop asking people to avoid a channel and start giving them an archived-by-default alternative they'll actually use.

Faster Due Diligence Responses

Institutional clients, consultants and platforms send long cybersecurity questionnaires. With current documentation and evidence, your team responds accurately and quickly, which keeps mandates moving and avoids overstating controls in writing. Your answers also stay consistent from one questionnaire to the next.

A CCO With Technical Backup

Most RIA compliance officers aren't technologists. Having an IT partner who explains controls in plain language, produces reports on request and joins exam conversations takes a heavy, specialized load off one person. Your CCO gets an engineer to call, not a ticket number.

Our Process

1
Review your compliance manual, last exam letter and Form ADV with your CCO to see what your policies promise about cybersecurity.
2
Inventory users, devices, platforms, communication channels and every service provider that stores or accesses customer information.
3
Enforce MFA and device management, then turn on archiving for email, chat and an approved texting channel and verify capture.
4
Write technical incident response procedures aligned with your Reg S-P program and run the first tabletop exercise with leadership.
5
Build the exam evidence package and map each policy statement to a control and a report your CCO can produce.
6
Deliver quarterly access reviews and evidence updates, support the annual review and adjust controls when rules or exam priorities change.

Frequently Asked Questions

What does the amended Regulation S-P require from our IT?▼
The 2024 amendments require covered advisers to adopt a written incident response program reasonably designed to detect, respond to and recover from unauthorized access to customer information, to oversee service providers and to notify affected individuals when sensitive customer information is reasonably likely to have been accessed or used without authorization. Your CCO and counsel own the program and notification decisions. We build the technical side: detection, logging, response playbooks, vendor inventory and evidence that the program operates.
Our advisors text clients. How do we fix that without banning it?▼
Give them an approved business texting option that captures messages into your archive, then set a clear policy against personal-channel business communications. Options include business numbers on managed phones or apps that integrate with your archiving vendor. We configure the solution, test that capture is complete and give your CCO review access. That approach supports Rule 204-2 recordkeeping and is far easier to enforce than a ban advisors quietly ignore.
We're state-registered, not SEC-registered. Does this still apply?▼
Regulation S-P applies to SEC-registered advisers, while state-registered advisers answer to their state securities regulator, and many states have adopted their own cybersecurity and recordkeeping expectations. The specifics vary, so your compliance lead should confirm which rules apply in each state where you're registered. The practical controls are largely the same either way: MFA, device management, archiving, vendor oversight and a tested incident plan. Building them now also eases a future move to SEC registration.
What will SEC exam staff ask about cybersecurity?▼
Requests commonly cover written policies, risk assessments, access controls, vendor oversight, incident response, training, data protection and any incidents you've had. Exam priorities change year to year, and your CCO should review the current published priorities. We keep an evidence package aligned to those areas and refresh it on a schedule. When a request letter arrives, we help your CCO assemble the technical portion and can join calls with exam staff on infrastructure topics.
How is an RIA different from a broker-dealer for IT purposes?▼
Both fall under Regulation S-P, but the rest differs. RIAs are fiduciaries regulated under the Advisers Act, with books and records under Rule 204-2 and a compliance program under Rule 206(4)-7. Broker-dealers answer to FINRA as well as the SEC, with specific rules for business continuity, supervision and electronic recordkeeping under Rule 17a-4. Dual registrants need both. We set up controls and evidence to match the registrations you hold. Hybrid firms often need extra care on archiving.
Can you work with our existing portfolio management and CRM vendors?▼
Yes. We don't replace your portfolio, CRM, planning or custodian platforms. We secure how your people access them with SSO and MFA where supported, review user permissions and include each vendor in the service provider inventory. When something breaks, we work with the vendor's support team so your operations staff don't have to. We support advisers in Texas and nationwide, mostly remotely, with local hands-on help when needed. Vendor changes get reflected in your inventory as they happen.
Do you provide Registered Investment Advisors IT Services in Houston and nearby areas?▼
Yes. LayerLogix is based in the Greater Houston area and delivers registered investment advisors IT services to businesses across Houston and the surrounding communities, including The Woodlands, Spring, Katy, Sugar Land, Conroe, Cypress, and Pearland. For most Houston-area clients we can be on-site the same day when something needs hands-on attention, and our help desk is available during business hours, with after-hours emergency support. Call 713-571-2390 to check coverage for your specific address.
What does Registered Investment Advisors IT Services cost for a Houston business?▼
Pricing depends on your size and what you need, so we do not publish a one-size-fits-all number — but Houston businesses generally pay a flat, predictable monthly fee rather than surprise hourly bills. We start with a free, no-obligation assessment of your current setup, then give you a clear quote in plain English with no hidden costs. That way you know exactly what you are getting and what it costs before you commit.

Ready to Get Started?

Contact LayerLogix today for a free consultation. We serve businesses throughout Houston, Dallas, Austin, and the surrounding Greater Houston area.

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