On July 7, 2026, SEC Chairman Paul Atkins issued a statement regarding the SEC’s 2026 Regulatory Agenda. The agenda reflects the Commission’s current emphasis on modernization, regulatory relief, technological innovation, capital formation, digital assets, and expanded retail access to private markets. Several of the planned initiatives could directly affect SEC-registered investment advisers. Others may affect only private fund advisers, registered fund advisers, or firms wi

A case from earlier this year provides insight into key areas that registered investment advisory firms should review to help identify and address potential gaps in their compliance programs. Reviewing SEC enforcement cases can help firms identify regulatory priorities, test portions of their own compliance programs, and discuss potential concerns with their internal and external compliance resources. This case details the following violations: · Hedge clause and liabi

Advisory fee billing is one of the most important areas for investment advisers to review periodically. It is also an area where errors can occur even when the firm has strong intentions, experienced personnel, and established systems. Many firms rely on custodians, portfolio management systems, billing software, spreadsheets, or internal operations personnel to calculate advisory fees. These tools can be helpful, but they do not eliminate the adviser’s responsibility to ensu

For SEC-registered investment advisers, the annual compliance review is not optional. Rule 206(4)-7 under the Investment Advisers Act of 1940 requires each registered adviser to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act and its rules. The rule also requires the adviser to review those policies and procedures at least annually to determine whether they are adequate and being implemented effectively. In pra

The SEC Division of Examinations issued a Risk Alert on June 9, 2026, addressing examination observations involving investment adviser economic conflicts of interest. The Risk Alert focuses on economic incentives advisers and their financial professionals may have when recommending products, services, account types, cash management programs, custodial arrangements, or fee structures. The SEC noted that examination staff observed conflicts that were undisclosed, incompletely d

The SEC recently published its Draft Strategic Plan for Fiscal Years 2026 through 2030. Although the plan does not create new compliance obligations, it provides useful insight into the SEC’s policy direction and the areas SEC-registered investment advisers may want to keep in mind as they prepare for annual review season. The plan emphasizes the SEC’s core mission of investor protection, fair and efficient markets, and capital formation. For investment advisers, that means t

Coulter Strategic Services is pleased to share that the firm has been added to the Kitces Advisor Services Map under the Compliance Consulting category. Kitces.com, founded by Michael Kitces, is a well-known industry platform providing financial planning commentary, advisor education, practice management resources, research, and other content for financial advisors. The Kitces Advisor Services Map is a resource for financial advisors seeking outsourcing and service providers

As advisory firms prepare for the amended Regulation S-P requirements, cybersecurity is no longer just an IT issue. The SEC’s expectations increasingly focus on whether a firm’s written policies, vendor oversight, and public disclosures align with actual practice, with potential consequences that can reach the executive level. The attached guest article by Brian Hahn of MTradeCraft walks through the practical implications for firm leadership, including third-party risk (espe

Regulatory technology (“RegTech”) continues to evolve, and many advisory firms are reassessing how technology can support oversight, documentation, and risk management to help control compliance-related costs without requiring a proportional increase in internal staffing or manual effort. For some firms, manual processes remain workable. For others, increasing regulatory expectations, staffing constraints, and operational complexity are prompting a closer look at whether tech

Effective compliance programs stay ahead of regulatory developments rather than reacting to them at the last minute. Whether you are new to the team, experienced in the role, or somewhere in between, being proactive is a skill that helps protect clients, strengthen operations, and reduce exam-related surprises. Regulatory expectations evolve quickly, and firms that monitor updates in a structured way are far better positioned to adapt without disruption. Establish a Consisten

Stepping into the Chief Compliance Officer role for a registered investment adviser can feel overwhelming, whether you are a dedicated compliance professional or an owner or principal who has taken on the CCO title. This is true even if day-to-day tasks are delegated to support staff or an outside compliance consultant, because responsibility for the program ultimately remains with the firm and its CCO. The key is to pause, assess, and rebuild on a sound foundation before mak

In its September 2025 order, the Securities and Exchange Commission found that a registered investment adviser violated the Marketing Rule , recordkeeping requirements, and the annual compliance review obligation under Rule 206(4)-7. The adviser made a prominent claim on its website that it “refuse[d] all conflicts of interest,” while its own compliance manual acknowledged that “conflicts of interest are inherent in the role as an investment adviser.” The SEC concluded that t

Artificial intelligence is now a standard part of the cyber landscape, and the recent disclosures involving Anthropic and its Claude model have become a clear warning for financial advisory firms. The incident did not involve advisory firms directly, but it revealed a level of data exposure that all firms need to understand and address. What Happened Anthropic reported that a state-sponsored group in China used the Claude and Claude Code models to support targeted cyberattack

The SEC’s July 2025 administrative action against a former Chief Compliance Officer underscores a simple but critical truth: integrity of the compliance record is non-negotiable. According to the Commission’s findings, the CCO “altered, fabricated, and caused others to fabricate” pre-clearance records to make it appear that certain trades had been properly reviewed and approved before execution when, in fact, they had not. These altered documents were then provided to SEC exa

The SEC’s 2025 enforcement action against a registered investment adviser highlights how routine administrative shortcuts, rather than intentional theft, can still lead to severe fiduciary violations. The Commission alleged that advisory personnel charged millions of dollars in unauthorized fees by directly accessing client brokerage accounts using client credentials and rerouting multi-factor authentication (“MFA”) codes to firm devices. According to the complaint filed in f

Growth through acquisition can bring exciting opportunities new clients, expanded resources, and greater scale—but it also introduces one of the most complex challenges a firm can face: merging two compliance programs into one. Whether your firm is acquiring another practice or integrating into a new organization, compliance should be part of the process from the very beginning, not after the documents are signed. Engage Compliance Early in the Process Compliance should play

For registered investment advisers, the written Policies and Procedures Manual and Code of Ethics are required components of the compliance program under the Investment Advisers Act of 1940. These documents form the operational foundation of an adviser’s compliance framework and are among the first items regulators review during an examination. A well-crafted manual should accurately reflect how the firm operates, supervises its personnel, and manages risk. By contrast, a gen

Introduction For many advisory firms, the annual compliance review is a recurring line item on the calendar, one that too often becomes a documentation exercise rather than a diagnostic one. Under Rule 206(4)-7, however, the annual review is a cornerstone of every adviser’s compliance program. Done well, it is not only a regulatory requirement but also an operational stress test that can highlight both compliance gaps and business inefficiencies. While the rule itself is conc

A recorded discussion with Coulter Strategic Services and MTradeCraft on the responsible use of artificial intelligence in advisory firms. This session covers privacy considerations, compliance steps under SEC requirements, and practical ways to use AI tools securely and effectively. Learn how to protect client data, improve output quality, and align AI use with your firm’s fiduciary and regulatory obligations. All information provided is for educational purposes and shall no

Artificial Intelligence (AI) is transforming how investment advisers analyze data, communicate with clients, and deliver services. But...