Serving accounting and advisory firms (tax and insurance or annuities)

CPA & ADVISORY FIRMS

Be ready when a regulator, a client, or a buyer says: “Show me.”

Reviewers can’t grade effort—only documented proof. Borealis builds and runs a cyber governance program for CPA and advisory firms (11–50 employees) and keeps evidence current in Aurora Command (the compliance portal). You can defend FTC Safeguards expectations and client diligence requirements without building a second program.

Answer “show me” in minutes, not weeks.

Confidential • Built around FTC Safeguards + client diligence expectations • 30 minutes • No obligation

PROGRAM SNAPSHOT

Built for Firm Reality, Not Single‑Framework Compliance

  • Built around the real “compliance gap”: FTC Safeguards baseline and client diligence pressure
  • Works alongside your MSP. No replacement, no helpdesk takeover
  • Evidence-first: every requirement mapped to proof, owned, and printable/exportable on demand
  • Built for the moments that matter: E&O renewals, regulator scrutiny, client due diligence, and M&A diligence
  • Multi‑state friendly: one program, with clear deltas by state

Remote-friendly kickoff. Low disruption for staff.

Good fit if:

  • You provide advisory services and handle sensitive client financial data
  • You operate in multiple states and want one defensible program
  • You want to protect valuation as partners exit or PE diligence intensifies
  • You have an MSP but need governance ownership, cadence, and evidence

Not a fit if:

  • You want an MSP replacement or daily IT operations provider
  • You want “templates only” without operating a living program
  • You only prepare a small number of seasonal returns and do not need a full governance program

Your MSP runs IT. Governance and evidence are a different job.

Tools reduce risk. Governance makes it defensible. Firms get squeezed because expectations come from multiple directions, and “we have security tools” isn’t proof.

Why the pressure is increasing

Regulators set the baseline. Clients bake it into questionnaires. Procurement and diligence teams repeat the questions. The pressure converges on one place: your firm.

Here’s where it hits first:

Client and Buyer Diligence

Questionnaires and diligence requests require fast, consistent answers backed by current evidence.

Fast notification windows

You don’t want to learn the window under pressure. You want checklists and roles already defined.

Valuation & timeline

Unclear applicability and weak documentation become leverage. Clean governance reduces uncertainty.

The questions you’ll get asked

Who is your Qualified Individual, and where is the authority documented? Named accountability with documented authority
Show your written program and last review (FTC baseline and overlay alignment). Current policy that matches operational reality
Show your risk system: assessment, register, treatment decisions, and remediation tracking. Owners, dates, and documented remediation
Show incident readiness and notification timing, especially for fast state windows. Tested and documented response capability
Show vendor oversight for custodians, platforms, MSP, DMS, portals, payroll, and e‑signature. Third-party risk management with evidence
Prove this is operated year-round, not assembled when asked. Continuous governance with dated evidence
If you’re licensed in multiple states, show what changes by state and how you track it. Multi-state awareness with exportable proof

The Governance Program

One operating system for governance. Clear overlays where state privacy and breach expectations apply. Evidence kept current.

Program Spine

  • FTC Safeguards-aligned written program, tailored to how you operate
  • Overlay alignment for applicable state privacy and breach expectations
  • Governance structure: roles, approvals, documented responsibility
  • Policies that match reality (not shelfware)

Risk System

  • Risk assessment (annual and updated on material changes)
  • Risk register with owners, dates, and treatment decisions
  • Remediation roadmap that your MSP can execute without churn

Incident & Notification Readiness

  • Incident Response Plan with playbooks
  • Notification readiness for fast windows (with role clarity and checklists)
  • Tabletop exercises with evidence that stands up to scrutiny
  • “Determination worksheet” and timeline capture template

People & Vendors

  • Access governance (MFA, joiner/mover/leaver, access reviews)
  • Vendor inventory, minimum requirements, and review cadence
  • Security awareness evidence

Can you produce evidence on demand?

Every control mapped to proof. Every proof owned. Evidence maintained continuously.

Evidence mapping index
Evidence requests & reminders
Evidence library
Print‑ready Audit Workbook and clean diligence exports

Everything is tracked in Aurora Command.

One place for governance tasks, decisions, and evidence. One place to export calm answers.

  • See what’s due before it becomes urgent
  • Assign owners so governance doesn’t live in your head
  • Export clean packets for regulators, buyers, and diligence teams

Nationwide Baseline and State Overlays

Aurora Command is built around the FTC Safeguards Rule baseline. State privacy and breach overlays are added as new requirements take effect, so you build once, operate once, and export to match the request.