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

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