Cybersecurity for RIAs and family offices
RIA Cybersecurity for Wealth Managers and Family Offices
RIA cybersecurity comes down to questions examiners, custodians, and clients all ask: who can reach client data, who can move client money, and what happens when an account is taken over. Invadel tests wealth managers, broker-dealers, and family offices at a fixed price, with a free retest and evidence for your Regulation S-P file.
The stakes
Why wealth managers get tested differently
Attackers go after wealth managers for client money and client identity. A client’s email is taken over and used to request a distribution. An adviser’s mailbox is compromised and used to send clients new wire instructions. A caller posing as a client asks the service team to change a bank account. FINRA’s 2026 oversight report names account takeovers, account impersonations, new account fraud, and imposter sites among the threats firms face. For a family office, the principals are the target, and their public profile writes the pretext.
The rules changed recently. Regulation S-P, amended in 2024, now requires SEC-registered advisers and broker-dealers to run a written incident response program, notify affected clients within 30 days, and make service providers report breaches within 72 hours, and smaller firms have had to comply since June 3, 2026. The SEC’s 2026 examination priorities list the amendments. Regulation S-ID adds an identity theft program for covered accounts. A single-family office sits outside the Advisers Act, but New York’s SHIELD Act still asks any business holding residents’ private information to test its key controls regularly.
A wealth management firm rarely has much of a perimeter to scan. Client data lives in Microsoft 365, the CRM, the planning software, the custodian’s platform, and a document portal, and client money moves on a request by email or phone. A generic external test says the firewall looks fine. The useful test starts from a phished adviser or a spoofed client, follows the access into the systems that hold households’ data, and checks whether the callback and approval steps stop a fraudulent request.
What we test
The systems attackers go after first
Adviser email and identity
Microsoft 365 or Google Workspace, tested for MFA gaps, mailbox forwarding rules, and conditional access that fails to stop a stolen session from reading client correspondence.
Client portals and document vaults
Where households view statements and exchange tax documents, tested for access between households, weak invitation and reset flows, and files reachable without a login.
CRM and planning platforms
Hosted CRM, financial planning, and reporting tools, reviewed for excessive permissions, shared logins, bulk export rights, and the API tokens that connect them to other systems.
Money movement workflows
Distribution requests, standing letters of authorization, and bank-change requests, tested with email and voice pretexts against service staff, stopping before any money moves.
Custodian and vendor access
Custodian platforms, outsourced IT, and other service providers, reviewed on the firm’s side for shared credentials, standing remote access, and accounts with no second factor.
Principals and household staff
For family offices, phishing and voice pretexts built from what is publicly findable about the family, aimed at the assistants and staff who handle bills, travel, and wires.
Compliance
The frameworks that usually apply
- SEC Regulation S-P
The 2024 amendments for SEC-registered advisers and broker-dealers: a written incident response program, client notice within 30 days, and oversight of service providers.
FINRA rules for broker-dealers
FINRA’s 2026 oversight report lists Regulation S-P, Regulation S-ID, Rule 3110 on supervision, and Rule 4370 on business continuity among the rules behind a broker-dealer’s cybersecurity program.
- NYDFS 23 NYCRR 500
Annual penetration testing for trust companies and other wealth businesses operating under a Department of Financial Services charter or license.
- New York SHIELD Act
Reasonable safeguards, including regular testing of key controls, for any business holding New York residents’ private information, family offices included.
Services
What wealth managers and family offices usually buy
- From $4,200
Microsoft 365 Security Assessment
A manual review of your Microsoft 365 or Google Workspace tenant: identity and MFA, mail security, sharing, and OAuth apps, plus an optional attack simulation. From $4,200.
- From $3,600
Phishing Simulation & Social Engineering Testing
Phishing and social engineering campaigns that measure real-world human risk, with click and credential metrics by department, from $3,600.
- From $4,200
External Network Penetration Testing
Testing of your internet-facing perimeter, from exposed services and VPN gateways to mail and cloud edges, with a free retest, from $4,200.
- From $5,200
Web Application Penetration Testing
Manual testing of your web application across the OWASP Top 10, business logic, and all user roles, with a free retest included, from $5,200.
- From $6,000
Internal Network Penetration Testing
Testing from an assumed foothold inside your network: Active Directory attack paths, lateral movement, and segmentation, from $6,000.
Regulations
RIA cybersecurity rules and who they cover
Which rules apply depends on how the firm is registered. None of them names a testing method, and each expects safeguards the firm can show were tested. This is how they line up for advisers, broker-dealers, and family offices.
Regulation S-P, as amended in 2024
- Who it covers
- SEC-registered investment advisers, broker-dealers, investment companies, funding portals, and registered transfer agents
- What it asks for
- Written safeguards for customer information, and an incident response program to detect, respond to, and recover from unauthorized access. Notice to affected individuals within 30 days, service providers that report breaches within 72 hours, and written records of compliance. Larger firms by December 3, 2025, smaller firms by June 3, 2026. See Regulation S-P requirements.
Regulation S-ID
- Who it covers
- Advisers and broker-dealers registered, or required to be registered, with the SEC that offer or maintain covered accounts
- What it asks for
- A written identity theft prevention program that detects, prevents, and mitigates identity theft when accounts are opened and on existing accounts.
FINRA Rules 3110 and 4370
- Who it covers
- FINRA member broker-dealers
- What it asks for
- Supervision and business continuity planning, which FINRA’s 2026 oversight report ties to cybersecurity alongside Regulations S-P and S-ID.
23 NYCRR 500
- Who it covers
- Firms operating under a New York Department of Financial Services license, charter, or registration, such as a New York trust company
- What it asks for
- Penetration testing from inside and outside the information systems at least once a year, plus automated vulnerability scans.
SEC family office rule
- Who it covers
- Single-family offices that serve only family clients, are owned and controlled by the family, and do not hold themselves out to the public as advisers
- What it asks for
- Excludes the office from the definition of investment adviser, so Regulations S-P and S-ID do not reach it directly. A multi-family office serving unrelated families cannot use the exclusion. If it registers with the SEC, Regulation S-P applies, and so does Regulation S-ID where it offers or maintains covered accounts.
New York SHIELD Act
- Who it covers
- Any person or business holding computerized private information of a New York resident
- What it asks for
- Reasonable administrative, technical, and physical safeguards, including regular testing and monitoring of key controls, systems, and procedures, and service providers bound to safeguards by contract.
Summaries of the primary sources as of September 2026: 17 CFR 248 (Regulations S-P and S-ID), 17 CFR 275.202(a)(11)(G)-1, 23 NYCRR 500, New York General Business Law 899-bb, and FINRA’s 2026 Annual Regulatory Oversight Report. The SEC withdrew its separate proposal for an adviser cybersecurity rule in June 2025. Confirm your own obligations with counsel.
How it runs
Typical engagements
Illustrative scopes for this industry, written to show what a test covers and what you walk away with.
They are not client stories; our anonymized engagements are on the case studies page.
Typical engagement
Independent RIA testing its Regulation S-P program
An independent RIA has written the incident response program Regulation S-P now requires and wants to know whether it would work. We review the Microsoft 365 tenant, then take over a test mailbox the way an attacker would and measure how long the firm takes to notice. A phishing campaign covers every adviser and assistant. The chief compliance officer receives the findings, a detection timeline to test the program against, and retest evidence for the compliance file.
Typical engagement
Multi-family office testing its principals’ exposure
A multi-family office worries that its families’ public profile makes its staff easy to fool. We build email and voice pretexts from what is publicly findable about the families, aim them at the staff who pay bills and arrange wires, and stop every attempt at the request. An external test covers the office’s remote access. The chief investment officer receives a private readout, and the callback procedure is rewritten before the next round of distributions.
Typical engagement
Hybrid adviser launching a client portal
A hybrid RIA and broker-dealer is replacing emailed statements with a client portal and document vault. We test the portal across client, household, adviser, and administrator roles, and the upload, e-signature, and account-linking flows. An adviser account can open households assigned to other advisers, because the portal checks the firm and not the adviser. The vendor ships a fix, we retest at no cost, and the firm launches with an attestation letter on file.
FAQ
What advisers and family offices ask
01What does Regulation S-P require of an RIA now?
Since the 2024 amendments, an SEC-registered adviser needs written policies for an incident response program that can detect, respond to, and recover from unauthorized access to customer information. It must notify affected individuals within 30 days when sensitive customer information was, or is reasonably likely to have been, accessed without authorization, and oversee service providers so they report breaches within 72 hours. Larger firms had to comply by December 3, 2025 and smaller firms by June 3, 2026. The rule does not name penetration testing, but a test shows the safeguards and the response program were exercised. Our Regulation S-P page covers the rest.
02Does Regulation S-P apply to a family office?
Not to a single-family office that meets the SEC’s family office rule. An office that serves only family clients, is owned and controlled by the family, and does not hold itself out as an adviser is not an investment adviser under the Advisers Act. A multi-family office that serves unrelated families cannot use that exclusion, and if it is registered with the SEC, Regulation S-P applies. Either way, New York’s SHIELD Act applies to any business holding New York residents’ private information and lists regular testing of key controls among its safeguards.
03Where should an RIA start?
With email and money movement, because that is where most losses begin. A Microsoft 365 or Google Workspace security assessment from $4,200 reviews MFA, conditional access, and mailbox forwarding rules, and a phishing campaign from $3,600 measures who clicks and who reports. Add a client portal test once clients log in to something you run. Managers of pooled funds facing allocator due diligence will find that covered on our hedge fund and asset manager page.
04Can you test our wire and distribution controls without moving money?
Yes. Pretexts run by email, phone, and text against the staff who take distribution and bank-change requests, and every attempt stops at the request: no money moves and no client account is touched. The chief compliance officer approves the pretexts in advance. The report shows who verified the request by calling back on a known number, who did not, and where the procedure broke. Our guide to voice phishing explains why the phone is often the weaker channel.
05How much does penetration testing cost for a wealth management firm?
A Microsoft 365 or Google Workspace assessment starts at $4,200, external network testing at $4,200, a phishing campaign at $3,600, client portal testing at $5,200 as a web application test, and internal network testing at $6,000. Each price is fixed in writing before work starts, and penetration tests include a free retest of remediated findings. A typical first engagement pairs the Microsoft 365 assessment with a phishing campaign, quoted as one number. See our penetration testing pricing.
06Do you work on site in Westchester and Connecticut?
Yes. We are headquartered at 1178 Broadway in Manhattan and meet advisers and family offices in person for scoping and readouts. We work on site across Westchester County and with funds, advisers, and family offices in Stamford and Greenwich. External, portal, and email testing run remotely, and internal testing runs through a small device we ship to your office.
Get a fixed price for your firm or family office
Tell us what needs testing. You get a written fixed price within one business day, with the compliance mapping your auditors and customers expect.
Prefer the full scoping questionnaire?Get a Fixed-Scope Quote
Tell us what you need tested. We reply within one business day.
Thanks, we've received your message.
We'll be in touch shortly.