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SEC’s 2026 Regulatory Agenda: New Rules Are Coming
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

Coulter Strategic Services
Jul 89 min read


Compliance Lessons from an SEC Enforcement Case: Advisory Agreements, Custody, and Policies and Procedures.
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

Coulter Strategic Services
Jul 18 min read


Annual Compliance Reviews
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

Coulter Strategic Services
Jun 155 min read


A Recent SEC Risk Alert Provides Roadmap to Common Examination Deficiencies
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

Coulter Strategic Services
Jun 127 min read


Practical Guidance to Manage the Annual Review and Strengthen Compliance Oversight.
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

Coulter Strategic Services
Oct 16, 202510 min read


AI in Advisory Firms: Innovation with Responsibility
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

Coulter Strategic Services
Oct 13, 20251 min read


A New Direction at the SEC—What It May Mean for Advisory Firms
April 10, 2025 With Paul Atkins confirmed on April 9, 2025, as Chair of the U.S. Securities and Exchange Commission , a shift in tone is...

Coulter Strategic Services
Apr 10, 20252 min read


Navigating Fiduciary Duty and Social Media: Lessons from a Potential Market Manipulation Case
Recent regulatory scrutiny has highlighted how the misuse of social media can blur the lines between personal market opinions and...

Coulter Strategic Services
Feb 27, 20256 min read
Financial Fraud: A Comprehensive Guide of practical tools and actions for Investment Firms.
The financial exploitation of seniors and vulnerable adults is an increasing concern in today's society. As the population ages, the...

Coulter Strategic Services
Oct 31, 202411 min read
Financial Fraud: A Comprehensive Guide of practical tools and actions for Investment Firms.
Introduction The financial exploitation of seniors and vulnerable adults is an increasing concern in today's society. As the population...

Coulter Strategic Services
Oct 28, 202411 min read


Proposed SafeGuarding Rule (Custody)
Proposed Rule: Enhanced Safeguarding Rule for Registered Investment Advisers (Proposed Date: February 15, 2023) The proposed Enhanced...

Coulter Strategic Services
Oct 2, 20244 min read


Adapting to New Requirements: A Guide to the Amended Regulation S-P
Advisory firms are subject to various regulations aimed at safeguarding client data, including the Red Flags Rule under the Fair Credit...

Coulter Strategic Services
Sep 20, 20247 min read
PROPOSED REGULATORY RULES THAT WILL POTENTIALLY IMPACT ADVISORY FIRMS
As the regulatory landscape for Registered Investment Advisers (Firms ) continues to evolve, staying ahead of proposed rules is crucial...

Coulter Strategic Services
Aug 20, 20246 min read


Navigating Hypothetical Performance Under the SEC Marketing Rule: Comprehensive Guidance
Introduction Hypothetical performance is a key component of the SEC’s Marketing Rule, which imposes specific criteria that firms must...

Coulter Strategic Services
Aug 13, 20246 min read


Learning from the CrowdStrike and Microsoft Global Outage: A Crucial Lesson for Registered Investment Advisory Firms
The recent global outage caused by a faulty CrowdStrike update, which affected Microsoft Windows systems worldwide, serves as a critical...

Coulter Strategic Services
Aug 5, 20243 min read


Balancing Innovation with Regulatory Compliance
We are pleased to announce the release of an insightful pre-recorded presentation titled "Balancing Innovation with Regulatory...

Coulter Strategic Services
Jun 23, 20243 min read


Artificial Intelligence - Balancing Innovation with Regulatory Compliance
We are pleased to announce the release of an insightful pre-recorded presentation titled "Balancing Innovation with Regulatory...

Coulter Strategic Services
Jun 21, 20243 min read


Compliance Lessons We Can Learn from an ETF Enforcement Case
The recent SEC enforcement action against Van Eck Associates Corporation (VEAC) offers several valuable compliance lessons for registered...

Coulter Strategic Services
Jun 11, 20244 min read


Mutual Fund Share Classes: Don't Forget to Review for Proper Share Classes as an Advisor
Introduction Mutual fund share classes have distinct characteristics that directly impact investment returns through varying fees and...

Coulter Strategic Services
May 20, 20246 min read


Annual Review: Requirements and Implementable Guidance
The recent amendments to Rule 206(4)-7 under the Advisers Act mark a significant shift in regulatory requirements for investment advisers...

Coulter Strategic Services
May 6, 20244 min read
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