HYBRID CPA & ADVISORY FIRMS
Be ready when the FTC, a state insurance commissioner, or a buyer says: “Show me.”
Effort doesn’t count. Proof does. Borealis builds and runs a dual‑framework cyber governance program for hybrid firms (11–50 employees) and keeps evidence current in Aurora—so you can defend FTC Safeguards expectations and NAIC‑style state insurance data security requirements without running two separate programs.
Answer “show me” in minutes, not weeks.
Built for hybrid reality—not single‑framework compliance
- Built around the real “compliance gap”: FTC Safeguards baseline + state insurance overlays when applicable
- 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, commissioner 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:
- Your firm (or partners) sell insurance/annuities for planning, benefits, or wealth strategies
- 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 seasonal tax returns with no advisory/insurance activity
Your MSP runs IT. Governance and evidence are a different job.
Tools reduce risk. Governance makes it defensible. Hybrid firms get squeezed because they must answer to more than one regime, and “we have security tools” isn’t proof.
The Shift
Hybrid firms are no longer just tax compliance shops. Once insurance activity enters the picture, you may be held to stricter expectations—often with faster notification timelines and state‑specific nuances.
The Compliance Gap
FTC Safeguards gives you a baseline. But state insurance data security laws add overlays—and the questions from commissioners, carriers, and diligence teams expect you to know where you stand on both.
Welcome to the compliance squeeze.
Regulators set the baseline. State insurance oversight adds overlays. E&O and cyber insurance repeat the questions. Diligence teams expect proof.
Here’s where it hits first:
Insurance/wealth diligence
When a partner holds a license or insurance products are in play, state expectations follow.
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
The Hybrid Governance Program
One operating system for governance. Clear overlays where state insurance expectations apply. Evidence kept current.
Program Spine
- FTC Safeguards-aligned written program—tailored to how you operate
- Overlay alignment for applicable state insurance expectations
- Governance structure: roles, approvals, documented responsibility
- Policies that match reality (not shelfware)
Risk System
- Risk assessment (annual + 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” + timeline capture template
People & Vendors
- Access governance (MFA, joiner/mover/leaver, access reviews)
- Vendor inventory + minimum requirements + review cadence
- Security awareness evidence
Can you produce evidence on demand?
Every control mapped to proof. Every proof owned. Evidence maintained continuously.
Everything is tracked in Aurora.
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 commissioners, insurers, and diligence teams
SYSTEM OF RECORD
No more spreadsheet chaos.
Aurora is included with all governance programs.
Nationwide Baseline + State Overlays
Aurora supports a federal baseline with state insurance overlays where applicable—so you build once, operate once, and export to match the request.
Hover a state to see the summary. Overlay states link to dedicated requirements pages; baseline states link to the nationwide checklist.
Licensed in multiple states?
We map once and show you what changes by state—without multiplying programs.
Choose how governance responsibility is handled
You retain the Qualified Individual (QI) internally
Best for firms with an internal leader who can execute tasks but needs structure, cadence, and defensible evidence. Your named security owner keeps the role; we provide the system, evidence map, and accountability.
- We help you select the right framework
- We provide the governance model
- We help you design your policies
- The Aurora portal helps you stay on track
- You keep the regulatory burden
For People Who Want to Run Their Own Show
We serve as your QI and operate the program
For firms that want governance operated, not just assigned. We serve as your Qualified Individual, run the cadence, document decisions, and keep a clean evidence trail for renewals, questionnaires, and diligence.
- We help you establish or refresh your governance program
- We manage your daily governance model
- We serve as your Qualified Individual and provide CISO-level advisory services
- We take the stress off your hands
For People Who Want Full Support
Advisory Track gives you the system. Managed Track gives you the system and the operator.
What happens after you book
30‑minute Program Review
We discuss firm size, services, tech stack, and current governance posture.
Scope & Proposal
You receive a tailored proposal with clear deliverables and timeline.
Build Phase Kickoff
Remote-friendly onboarding. We build the program foundation while keeping staff disruption minimal.
The Build
One-time setup. We build the governance engine.
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Program Scope Services, data types, vendor stack, MSP boundaries, insurance activity.
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FTC Safeguards-aligned Written Program Draft → finalize, with hybrid overlay alignment.
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Risk Assessment Initial risk assessment + risk register.
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Evidence Map Evidence map + print/export structure.
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Aurora Portal Setup Tasks, library, owners.
The Run
Monthly cadence. We keep you ready.
- Monthly accountability check-ins
- Evidence collection reminders
- Updates for material changes
- Guided questionnaire support
- QI/vCISO-led governance actions & oversight
- Higher-touch commissioner/insurer/diligence support
- Leadership-ready reporting & decision tracking
- Diligence packaging (clean evidence trail)
Aurora turns governance work into proof.
The program is operated by Borealis, but the work lives in Aurora. That’s where questionnaires, evidence, owners, and exports stay organized so you can answer “show me” without panic.
Compliance Governance
Turn requirements into an operating system: owners, cadence, decisions, 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 export clean proof packets on demand.
- Evidence library and indexing
- Requests, reminders, and follow-up
- Print-ready packets and diligence exports
Questionnaire Prep (service-first)
We help you respond faster without sending “trust me” answers.
- Reusable response library
- Evidence-backed answers
- Clean exports for reviews and renewals
Built for real questionnaires
Upload what you have today, get immediate coverage signals, then turn the rest into tracked requirements and remediation.
Ingest reliably
Bring questionnaires, evidence, and policies into one workspace.
See coverage
Know how many questions we can draft answers for right away.
Review + edit
Walk through the assessment, attach evidence, and preserve human edits.
Export cleanly
Export answers and evidence as structured files and audit-ready bundles.
SEE IT WORK
Get a guided Aurora walkthrough
We’ll show you how questionnaires flow into requirements, how evidence stays organized, and what a print-ready workbook looks like.
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 I just download templates?
Templates that aren’t operated become liabilities. We build policies that match operations and create the evidence trail that proves year-round operation.
We only “refer” insurance—does this still apply?
We scope your footprint and create a defensible position based on how products are offered, licensed, and marketed.
We’re licensed in multiple states—do we need multiple programs?
No. One operating system, with state overlays tracked and exportable.
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 compliance implementation firm. We help you implement defensible programs and evidence.
Can we do this without disrupting staff?
Yes. We keep staff asks 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 turn dual‑framework governance into proof?
Start with a 30‑minute conversation about your firm, your tech stack, and what “defensible” looks like for you.
Book a 30‑minute Program Review