Managed Governance for Accounting & Advisory Firms
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Governance for CPA & Advisory Firms

One Governance Program for FTC, Privacy, and Client Diligence

Regulators and clients expect proof your security program is current.

Borealis keeps one current program behind your tax, advisory, and diligence obligations so you can answer different reviewer requests without rebuilding the story every time.

Stop running separate compliance tracks. One core program can cover FTC, privacy, and client diligence, with state-specific differences mapped where needed.

Book a 30-Minute Program Review

30-Minute Review • FTC + Client Diligence Focus • No Obligation

PROGRAM SNAPSHOT

What the Program Covers

  • FTC Safeguards baseline and client diligence expectations
  • Works with your MSP or internal IT, does not replace it
  • Requirements mapped to proof, owned, and kept current
  • E&O renewals, client questionnaires, and M&A diligence ready
  • Multi‑state friendly: one program with clear deltas by state

Remote-friendly kickoff. Light lift for your team.

One Program Across Multiple Reviewer Pressures

Your firm handles tax data regulated by the FTC and wealth data scrutinized by clients and state laws. Running two separate compliance programs to cover both creates duplicate work and inconsistent proof.

Borealis maintains one operating model. We map your evidence once, then layer in the reviewer-specific outputs and state-specific deltas needed for the request in front of you.

Good fit if:

  • Your clients send security questionnaires before signing and you need defensible answers
  • You plan to sell or merge within three years and need clean governance to reduce diligence risk
  • You operate in multiple states and need one program that addresses requirements across jurisdictions

Not a fit if:

  • You need an MSP replacement or day-to-day IT operations
  • You want paperwork only, not a living, maintained program
  • You prepare a small number of seasonal returns and governance is not a priority

Core Evidence Reviewers Ask For

Client diligence and FTC Safeguards reviews tend to ask for the same core proof. These are reviewer evidence examples, not a universal legal answer that applies identically in every jurisdiction.

  • A current written program with named ownership and a documented review cadence
  • Risk assessment + risk register (findings, owners, decisions)
  • Vendor oversight (MSP and key platforms) with review notes
  • Incident readiness with documented breach-notice roles and timing
  • Training records and policy approvals (where applicable)
  • A maintained evidence set with reviewer walkthrough support
Book a 30-Minute Program Review

You Need Independent Governance, Not Just Technical Administration

Your MSP manages the technical controls. Borealis manages the governance record.
Independent oversight of your security program gives auditors and clients the separation of duties they expect.

The Reality Check

Borealis provides the independent governance layer that proves your MSP is doing their job, giving you the “checks and balances” narrative auditors typically expect.

The Compliance Gap

FTC Safeguards gives you a baseline. Clients and buyers add their own diligence requirements. Regulators and diligence teams expect you to know where you stand, and prove it.

If You Do Both Tax and Insurance/Annuity Work

  • A single program with clear ownership covers both tracks.
  • Where expectations differ, we document the requirement and keep the delta current.
  • You can answer different reviewer contexts from the same maintained evidence set.

One Core Program, Three Reviewer Contexts

CPA and advisory firms do not need three separate compliance programs. They need one maintained program that can answer FTC reviews, client diligence, and privacy questions without rebuilding the proof each time.

FTC Baseline

Your written program, risk system, and named ownership need to stay current enough to survive FTC Safeguards scrutiny and the follow-up questions that come with it.

Wealth-Client Diligence

High-net-worth and institutional prospects want proof that feels premium: consistent answers, visible operating discipline, and a clean reviewer handoff instead of generic assurances.

State and Privacy Requirements

Multi-state work changes notification timing and privacy expectations. Borealis tracks the requirement deltas so your team is not guessing which rule changed the response.

One Maintained Program. Three Clean Outputs.

  • One ownership model and evidence cadence inside Aurora Command
  • One reusable review path for client diligence, buyer review, and regulator pressure
  • One change log that shows what is baseline versus what is a requirement

The Questions Reviewers Will Ask

1
“Who is in charge?” Named accountability with documented authority, not a generic “IT Dept.”
2
Show your written program and last review (FTC baseline and requirement alignment). Current policy that matches operational reality
3
Show your risk system: assessment, register, treatment decisions, and remediation tracking. Owners, dates, and documented remediation
4
Show incident readiness and notification timing, especially for fast state windows. Tested and documented response capability
5
Show vendor oversight for custodians, platforms, MSP, DMS, portals, payroll, and e‑signature. Third-party risk management with evidence
6
Prove this is operated year-round, not assembled when asked. Continuous governance with dated evidence
7
If you’re licensed in multiple states, show what changes by state and how you track it. Multi-state awareness with current proof
Book a 30-Minute Program Review

The Governance Program

One governance cadence for both sets of expectations. Clear requirements where state privacy and breach rules apply. Evidence kept current.

Program Spine

  • FTC Safeguards-aligned written program, tailored to how you operate
  • Requirement 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 roles with clear escalation and recovery decisions
  • Notification readiness for fast windows (with role clarity and documented decision flow)
  • Tabletop exercises with evidence that stands up to scrutiny
  • Determination support and disciplined timeline capture

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?

Controls mapped to proof. Proof assigned to owners. Evidence maintained continuously.

Evidence Map Controls linked to their proof artifacts
Requests & Reminders Automated collection with owner notifications
Evidence Library Centralized, versioned, and searchable
Reviewer Handoff Controlled sharing with access tracking

Aurora Command

The System Behind Your Program: Aurora Command

Borealis uses Aurora Command to keep control mapping, evidence freshness, and controlled reviewer sharing aligned across FTC baseline obligations, privacy requirements, and client diligence.

Aurora Command framework requirements view showing one control set mapped across multiple frameworks and reviewer contexts. One program, many asks

Requirement Mapping

Keep one control set across FTC and state requirements

Advisory firms often need one maintained program that can answer FTC baseline obligations, state requirements, and buyer diligence without forking the evidence set.

  • Useful when the same firm faces overlapping reviewer lenses.
  • Reduces duplicate work across tax, advisory, and privacy requests.
  • Supports cleaner exports for different reviewer contexts.
Aurora Command evidence dashboard showing artifact health summary with active, expiring, and expired status indicators. Monthly cadence

Freshness + Timing

Keep evidence current between review cycles

Aurora Command surfaces freshness timing, approval history, and review status so Borealis can run a calm monthly cadence instead of a last-minute scramble.

  • Good evidence has an owner, a date, and a refresh cadence.
  • Review cycles stop depending on memory and inbox searches.
  • Borealis uses this to keep the program organized for review year-round.
Aurora Command Trust Centers dashboard showing controlled reviewer handoff with published portals and access request settings. Controlled handoff

Reviewer Handoff

Deliver the right evidence without attachment chaos

Aurora Command helps Borealis package the maintained evidence set into a deliberate handoff, so questionnaires and buyer reviews start from a current record instead of a scramble.

  • Useful when the buyer wants a believable trust and export path.
  • Reinforces the evidence-first story without email sprawl.
  • Makes the Aurora handoff feel intentional instead of abrupt.
Aurora Command Trust Centers dashboard showing published trust portals with public access controls and request workflow settings. Controlled sharing

Trust Center Access

Share proof through a controlled handoff

Aurora Command uses controlled access workflows instead of loose attachments, so buyers and reviewers get the right evidence without losing track of what was shared.

  • Cross-domain handoffs feel deliberate instead of abrupt.
  • Useful when procurement or diligence reviewers need selective access.
  • Supports a controlled proof handoff without email chaos.
See How Aurora Command Supports the Program Book a 30-Minute Program Review

Screenshots shown from the live public Aurora experience.

Borealis Baseline and State Requirements

The program starts with an FTC baseline, then adds the state-specific privacy and breach requirements you need to track before you send a response.

Hover a state to preview the summary. Click or tap a state to pin the summary. Press Escape to close a pinned summary.

State-specific requirements
Federal requirements (FTC Safeguards)

Hover or click a state to see the summary. Highlighted states show example requirements on top of the FTC Safeguards baseline.

High-level overview only (not legal advice). Requirements shown are illustrative and not exhaustive; confirm applicability with counsel.

Serving Clients in Multiple States?

We map once and show you what changes by state, without multiplying programs.

Book a 30-Minute Program Review

Choose Your Governance Model

If FTC Safeguards applies, the Qualified Individual is the named security-program owner. Other frameworks use different titles. Borealis can support the right ownership model without a full-time leadership hire.
ADVISORY TRACK

Advisory Track: your team keeps the Qualified Individual role

Best for firms with an internal owner ready to keep accountability in-house. Your team keeps the Qualified Individual role, while Borealis provides the system, structure, and monthly follow-through that keep the program current.

  • Aurora Command system + operating roadmap
  • Monthly prompts, reminders, and evidence cadence
  • Evidence map and reviewer handoff plan
  • Guidance for HNW diligence and buyer requests
  • You retain the legal Qualified Individual title (we keep you on track)
Book a 30-Minute Program Review See How Aurora Command Supports the Program

For teams who want to run the program in‑house

RECOMMENDED
MANAGED TRACK

Managed Track: Borealis supports your Qualified Individual requirements

Best for firms who want to transfer the weight. Borealis supports your designated Qualified Individual requirements where that FTC model fits. We maintain the WISP, run the governance cadence and risk-assessment process, and support the audit response. You still retain final legal responsibility for the firm.

  • Borealis supports your designated Qualified Individual requirements where that FTC model fits
  • We maintain the WISP and operating cadence
  • We run the risk-assessment process and documentation
  • We support audit and diligence responses while keeping the evidence current
Book a 30-Minute Program Review See How Aurora Command Supports the Program

For teams who want full support

Advisory Track: internal Qualified Individual with Borealis support. Managed Track: Borealis supports the Qualified Individual requirements.

What Happens After You Book

1

30‑Minute Program Review

We discuss firm size, services, tech stack, and current governance posture.

2

Scope & Proposal

You receive a tailored proposal with clear deliverables and timeline.

3

Build Phase Kickoff

Remote-friendly onboarding. We build the program foundation while keeping staff disruption minimal.

Phase 1

The Build

One-time setup. We build your governance foundation.

  • Program Scope Services, data types, vendor stack, MSP boundaries, advisory scope.
  • FTC Safeguards-aligned Written Program Draft to final, with baseline and state requirement alignment.
  • Risk Assessment Initial risk assessment and risk register.
  • Evidence Map Evidence map and reviewer handoff plan.
  • Aurora Command Setup Tasks, library, owners.
Phase 2

The Run

Monthly cadence. We keep you ready.

Advisory Track
  • Monthly accountability check-ins
  • Evidence collection reminders
  • Updates for material changes
  • Guided questionnaire support
Qualified Individual as a Service (FTC Safeguards) Adds
  • Qualified Individual governance actions & oversight with Borealis support
  • Higher-touch buyer and diligence support
  • Leadership-ready reporting & decision tracking
  • Diligence packaging (clean evidence trail)

How Borealis Delivers Through Aurora Command

Aurora Command is the system. Borealis runs the cadence around it so evidence stays current, proof stays reusable, and responses stay calm when client diligence arrives.

Compliance Governance

Turn requirements into a working cadence: owners, decisions, due dates, and a single source of truth.

  • Track requirements (including custom)
  • Assign owners and due dates
  • Turn gaps into remediation

Evidence Collection

Map controls to what proves them, keep evidence organized, and keep reviewer handoff clean and current.

  • Evidence library and indexing
  • Requests, reminders, and follow-up
  • Reviewer walkthrough support and clean handoff notes

Questionnaire Prep (Service-First)

We help you respond faster without sending “trust me” answers.

  • Reusable response library
  • Evidence-backed answers
  • Clean handoff support for reviews and questionnaires

Built for Real Questionnaires

Upload what you have today, see what’s covered, then turn the rest into tracked requirements and remediation.

1

Bring It Together

Bring questionnaires, evidence, and policies into one workspace.

2

See Coverage

See how many questions can be drafted from your approved policies and evidence.

3

Review and Edit

Walk through the assessment, attach evidence, and preserve human edits.

4

Hand Off Cleanly

Deliver answers and supporting evidence in a controlled, review-ready format.

SEE IT WORK

See How Aurora Command Supports the Program

See how questionnaires map to requirements, how evidence stays organized, and what a controlled review handoff looks like.

See How Aurora Command Supports the Program Book a 30-Minute Program Review

FAQ

Do you replace our MSP?

No. Your MSP runs IT operations and tooling. Borealis runs the governance layer: ownership, cadence, documentation, and evidence.

Can’t we just keep the documents ourselves?

Static documents without operating ownership become liabilities. Borealis ties the program to real owners, monthly follow-through, and evidence that matches the way your firm actually works.

We are an RIA / Wealth Management firm. Does FTC Safeguards apply?

It depends on your licensing and activities. Some RIAs fall under FTC Safeguards; others are covered by SEC Regulation S-P or state-level rules, and the obligations can overlap. We build a program that covers the FTC baseline and the higher expectations of wealth management. Consult with qualified legal counsel for guidance specific to your situation.

We’re licensed in multiple states. Do we need multiple programs?

No. One program, with state requirements tracked and ready for review.

We can’t disrupt tax season. Can we do this without chaos?

Yes. We plan around the calendar. Build in implementation season; maintain quietly during peak season; keep proof ready before January.

Do you provide legal, tax, or accounting advice?

No. We are a cybersecurity and governance implementation firm. We help you implement defensible programs and evidence.

Can we do this without disrupting staff?

Yes. What we need from staff is small and scheduled. Most work is leadership alignment, documentation, and evidence organization, done remotely with minimal interruptions.

Do you work nationwide even though you’re Alaska-based?

Yes. The program is designed for remote execution and multi-state realities.

Ready to See How Managed Governance Works?

Let us show you how Borealis builds and maintains the evidence your clients and reviewers expect.

Book a 30-Minute Program Review

30-Minute Review • FTC + Diligence Focus • No Obligation