GOVERNANCE PROGRAM
Technology Governance Program Guide
The Centience governance model — Assessment, Roadmap, and Program — built around your specific regulatory obligations.
Select your regulated body below to see governance program details tailored to your obligations.
SEC-registered firms face continuous governance obligations — not one-time assessments. The Centience model operates on a rolling calendar aligned to Rule 206(4)-7 annual compliance review, Regulation S-P ongoing safeguarding requirements, and the SEC's examination cycle. This guide covers how the Assessment, Roadmap, and Program phases translate specifically to SEC technology obligations.
1. Why SEC-Registered Firms Need a Governance Program
Rule 206(4)-7 annual compliance review, Regulation S-P ongoing monitoring, SEC examination priorities, and materiality determination for cybersecurity disclosure all require a functioning program — not a point-in-time document. • Annual compliance review is not optional — it is a regulatory requirement for registered investment advisers. • Regulation S-P safeguarding is continuous. Customer records must be protected at all times, not just during examinations. • SEC examination priorities change annually. Your governance program must adapt to current priorities. • Cybersecurity disclosure obligations require ongoing materiality monitoring — you cannot make materiality determinations without an active program.
2. Assessment Phase — SEC Focus Areas
The assessment phase establishes your governance baseline against SEC-specific requirements: • Regulation S-P Gap Analysis: Evaluate current safeguards against the 2024 amended requirements including 30-day customer notification. • Books and Records Audit: Verify WORM compliance, retention periods, and accessibility of all required records. • AI Governance Review: Inventory AI tools, assess conflict of interest risk, evaluate disclosure adequacy. • Cybersecurity Control Validation: Test technical controls against current SEC examination standards. • Vendor Risk Assessment: Review all third-party relationships with access to customer data. • Policy Currency Review: Evaluate all written policies against current SEC rules and guidance.
3. Roadmap Phase — SEC Remediation Priorities
The roadmap translates assessment findings into an executable remediation plan: • Critical (30 days): Active regulatory violations, unaddressed prior examination findings, material disclosure gaps. • High (90 days): Controls that would likely result in examination findings, significant policy gaps, vendor risk issues. • Medium (180 days): Compliance gaps with indirect examination exposure, documentation deficiencies, process improvements. • Low (Annual): Best-practice improvements, efficiency optimizations, emerging regulatory preparation. Each remediation item includes SEC rule citation, current enforcement context, and specific implementation guidance.
4. Ongoing Program — SEC Examination Calendar
The program phase maintains examination readiness continuously: • Monthly: Security monitoring review, privileged access review, vendor incident review, policy exception log. • Quarterly: Access review for customer data systems, governance dashboard for leadership, vendor due diligence refresh, penetration testing. • Annually: Full governance assessment refresh, policy review and update cycle, incident response tabletop, BCP/DR test, regulatory change management review, Rule 206(4)-7 annual compliance review.
5. SEC Examination Support
The governance program produces a standing evidence file that makes the standard SEC document request fulfillable within 24 hours: • Standard Document Request Response: Pre-assembled evidence file with all commonly requested technology documents. • Staff Preparation: Key personnel briefed on examination protocols and document preservation obligations. • Examiner Coordination: Single point of contact designated, production log maintained for all documents provided. • Post-Examination: Findings documented in risk register, remediation commitments tracked, follow-up examination preparation initiated.
6. SEC Governance Program Readiness Checklist
Governance program evidence that demonstrates a continuously operational compliance program: ☐ Current governance assessment with findings and remediation status ☐ Active remediation roadmap with milestone tracking ☐ Monthly/quarterly governance activity logs demonstrating continuous operation ☐ Standing evidence file with all standard SEC document request items ☐ Annual compliance review documentation per Rule 206(4)-7 ☐ Regulatory change management log showing program adaptation ☐ Board/leadership governance reporting history ☐ Staff training records including governance program orientation
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The Centience Governance Program
A guide tells you what’s required. The program makes it real — and keeps it that way.
Centience builds and operates the governance program behind these requirements — continuously, with audit-ready evidence. Start with a Governance Readiness Review.
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