IT Center delivers SEC Regulation S-P 2024 compliant managed IT for PE firms, hedge funds, family offices, and registered investment advisers. MNPI information barriers, VDR security, zero-trust deal team access, and 30-day breach notification readiness — all at $300/computer user/month.
Amended in May 2024, SEC Regulation S-P now requires registered investment advisers, broker-dealers, and transfer agents to notify affected customers within 30 calendar days of discovering a data breach involving customer financial information — replacing the former vague "without undue delay" standard. Non-compliance exposes your firm to SEC enforcement action, reputational damage, and LP attrition.
SEC Reg S-P requires a documented, board-approved IRP with defined roles, escalation paths, and annual tabletop exercises. IT Center designs and tests your IRP against realistic PE scenarios: VDR breach, ransomware on deal files, BEC wire fraud attempt.
The 30-day clock starts at discovery. Our 24/7 AI-powered SIEM — built on Microsoft Sentinel — correlates endpoint telemetry, VDR access logs, email gateway alerts, and network flows to detect intrusions before data leaves your environment, maximizing the window available for notification prep.
We pre-stage notification templates covering LP personal data, portfolio company PII, and fund subscriber financial information. When the clock starts, your compliance team has a ready-to-execute playbook — not a scramble for outside counsel at $1,000/hour.
Investment Advisers Act of 1940 Section 204 requires seven-year retention of electronic records. We configure immutable, WORM-compliant backups in Microsoft Azure and provide access logs, policy documentation, and incident records audit-ready for SEC examination staff.
Reg S-P 2024 extends obligations to service provider oversight. We inventory all third-party systems — fund administrators, accounting platforms, deal sourcing tools — perform annual vendor security assessments, and document contractual security requirements for your CCO.
SEC examination staff consistently request these documents from investment advisers during cybersecurity sweeps:
Material Non-Public Information (MNPI) — deal terms, target valuations, unreleased financials, merger negotiations — must be rigorously siloed from personnel who could trade on it. IT Center implements information barriers through network-level access controls, not just policy memos. We build Chinese walls that regulators can actually inspect.
Each deal team operates in a discrete Microsoft Entra ID security group with access scoped strictly to their deal's SharePoint site, shared mailbox, and Teams channel. Cross-team resource access is blocked at the policy layer — no exceptions without CCO approval workflow.
Every file open, SharePoint access, email send, and VDR login is logged and retained immutably in Microsoft Purview Audit for 7 years. Audit logs satisfy Investment Advisers Act recordkeeping requirements and provide forensic evidence if an insider trading investigation arises.
Active deals run on dedicated VLANs with firewall rules preventing lateral movement between deal teams. A junior analyst on Fund IV cannot reach the fileserver for a Fund III portfolio company exit — even on the same physical office network. Microsegmentation enforces the wall at Layer 2.
Microsoft Purview DLP policies detect and block outbound transfer of deal documents classified as Confidential or Highly Confidential. Sensitivity labels applied at creation travel with documents — preventing emailing a CIM to a personal Gmail account or uploading to a consumer cloud service.
Deal environments require hardware security keys (YubiKey or Windows Hello for Business) — not SMS or authenticator app codes, which are vulnerable to real-time phishing via adversary-in-the-middle (AiTM) attacks. FIDO2 passkeys eliminate credential theft as an attack vector for deal data.
Microsoft Defender for Cloud Apps and Microsoft Sentinel UEBA baseline each user's normal access patterns. After-hours bulk download of deal files, access from unexpected geography, or lateral movement across deal team boundaries triggers an immediate alert to our 24/7 SOC for investigation.
A VDR breach during live M&A due diligence can kill a deal, trigger litigation, and expose MNPI to adversarial buyers. IT Center integrates with all major VDR platforms to harden access, correlate activity logs with your internal SIEM, and enforce least-privilege document access for every counterparty user.
VDR access logs are pulled via API or SIEM connector and correlated against internal endpoint and network telemetry in Microsoft Sentinel. When a counterparty user downloads 400 documents in 10 minutes, your SOC sees it in real time — not during post-deal review.
We enforce just-in-time (JIT) access provisioning for external counterparty users — access expires automatically at deal close or when a buyer drops from the process. No orphaned external accounts with lingering access to your deal documents post-process.
Microsoft Entra ID Conditional Access policies require compliant, managed devices for internal users accessing VDR via corporate SSO. Unmanaged BYOD devices are blocked from downloading protected documents — they can view in-browser only, protecting against keyloggers on unmanaged machines.
Microsoft Purview sensitivity labels — Confidential, Highly Confidential, MNPI-Restricted — are applied to deal documents at creation. Labels encrypt documents, add watermarks, and prevent printing or screenshot capture based on classification level. Labels travel with the file outside the VDR.
Defender for Cloud Apps policies alert on bulk downloads, impossible-travel logins (New York at 9am, Tokyo at 9:05am), and access outside agreed due diligence hours. Automated response can suspend a counterparty account pending your deal team's review — without requiring your IT staff to be awake.
At deal close, LOI rejection, or process end, we run automated offboarding: VDR external account suspension, shared mailbox access removal, deal team VLAN access revocation, and Microsoft Teams channel archival. Full audit trail produced for CCO review. Zero lingering access guaranteed.
Private equity faces a concentrated set of high-consequence cyber threats. Each incident scenario below has destroyed firms: killed deals, triggered SEC enforcement, and driven LP departures. Here is how IT Center closes each exposure.
Business email compromise targeting capital call notices is the single highest-dollar PE cyber loss category. Attackers compromise a GP email account or spoof a CFO identity to redirect $2M–$50M wire transfers to attacker-controlled accounts. LPs receive fraudulent banking instructions.
Nation-state and competitive intelligence actors target CIMs, financial models, LOIs, and management presentations to gain pre-announcement trading advantage or feed to strategic competitors. A single exfiltrated CIM can compromise an entire deal and expose the firm to SEC insider trading investigation.
A ransomware attack encrypting your deal files during active due diligence is a deal-killing event. If the target company's M&A readiness data room, financial model, or VDD reports are encrypted two weeks before close, the deal likely dies — and the attacker knows it, demanding maximum ransom.
Institutional and individual LPs provide W-9s, FBAR-related documentation, SSNs, net worth statements, and bank account information during subscription. A breach of LP personal data triggers SEC Reg S-P 30-day notification, CCPA enforcement exposure, and LP confidence collapse — often leading to capital commitment withdrawals.
When an investment professional has inappropriate access to MNPI about a pending acquisition or portfolio company earnings release, the firm faces SEC enforcement regardless of whether the insider actually trades. Inadequate IT access controls are cited as a contributing factor in SEC MNPI cases, with firms paying $10M+ in penalties.
Self-service investor portals — where LPs view capital account statements, K-1s, and distribution notices — are often built on platforms with weak authentication and no session monitoring. A compromised LP account can expose all fund investors' financial data, triggering mass notification obligations.
Everything your firm needs to operate securely and pass SEC examination — included at $300/computer user/month. No add-ons required for compliance basics. No surprise invoices when a regulator asks for documentation.
Unlimited help desk support for all partners and staff. Remote resolution for M365, deal platforms, financial applications, and firm infrastructure. Sub-1-hour SLA for partner-level issues. No per-ticket fees — ever.
AI-native Security Operations Center monitors your endpoints, email, network, cloud workloads, and VDR access logs around the clock. Average threat containment under 12 minutes. SIEM powered by Microsoft Sentinel with 90-day hot log retention.
Design and implement technology-enforced information barriers between deal teams, fund operations, and public market investing personnel. RBAC architecture, network segmentation, DLP policies, and audit logging configured and documented for SEC review.
Written IRP, WISP, vendor risk management program, annual employee training, breach notification playbook, and exam-ready documentation package. We keep your compliance calendar current and your CCO informed of any changes to SEC cybersecurity guidance.
Integration with Intralinks, Datasite, Ansarada, and iDeals to feed access logs into your SIEM. Counterparty provisioning and deprovisioning workflows. Document sensitivity labeling. Post-deal access revocation with documented CCO audit trail.
DMARC enforcement for your domain, Microsoft Defender for Office 365 Plan 2 with BEC impersonation detection, out-of-band wire verification protocol for capital calls and deal closings, and executive impersonation monitoring with real-time alerting.
Immutable Azure Backup with 3-2-1-1-0 strategy. SharePoint versioning with 500-version retention. Defender for Endpoint automated ransomware rollback. Quarterly recovery drills with documented RTO/RPO results. Deal files recoverable in under 4 hours from last clean backup.
Microsoft Entra ID Privileged Identity Management (PIM) for just-in-time privileged access with approval workflows. Quarterly access certifications for all deal team memberships. Automated joiner/mover/leaver provisioning integrated with your HR system to eliminate orphaned accounts.
IT Center supports and secures the platforms PE firms actually use — from deal management to portfolio monitoring to LP reporting. We do not ask your firm to change how it operates; we secure the platforms you already depend on.
Most managed service providers offer the same package to every client: patch Tuesday, antivirus, help desk tickets. Private equity has fundamentally different requirements — SEC regulatory accountability, deal confidentiality at every layer, and LP fiduciary obligations that make a breach catastrophic beyond just financial loss.
Your WISP, IRP, and vendor risk management program are drafted and signed-off in the first 30 days. When the SEC calls, your CCO has the documentation. We have done this for registered investment advisers before — it is not a learning exercise for us.
We architect RBAC, network segmentation, and DLP policies specifically for PE deal team structures — including GP/LP separation, deal team/portfolio operations separation, and front-office/back-office controls. Our barrier documentation is structured for CCO presentation.
We layer security controls on top of your existing VDR platform — not instead of it. Counterparty access provisioning can be configured in under 2 hours. Access revocation is automated. Deal teams work in their existing tools with security running transparently underneath.
Deal close is already complex. At $300/computer user/month, your IT cost is predictable every month — regardless of how many support requests, how many incidents, or how many compliance documentation requests your CCO makes. We do not bill by the hour when regulators call.
Our team is in Corona, CA — serving the Inland Empire, Los Angeles, Orange County, and San Diego PE corridor. When you need on-site for a partner meeting, board presentation setup, or incident response, we are there — not dispatching a contractor from out of state.
We assess your current IT environment against SEC Reg S-P 2024 requirements, identify MNPI information barrier gaps, and provide a written remediation roadmap — all at no cost, with full confidentiality. Most assessments are completed within 5 business days.
Complete confidential. No sales pressure. Response within one business day.