NASAA published its annual report on state-registered investment advisers on September 8, 2025, summarizing the work of state securities regulators, who collectively oversee more than 16,000 investment advisers — generally those with $100 million or less in assets under management.
The most common deficiency drivers identified were failure to register as an investment adviser or investment adviser representative, improper fee practices, fiduciary-duty violations, and inadequate written compliance policies and procedures.
Additional frequent findings included failure to disclose conflicts of interest, violations of a firm's own stated policies, improper handling of private placements, and issues related to custody and books and records.
NASAA's coordinated examination program publishes recommended best practices alongside these findings to help state-registered advisers strengthen registration accuracy, recordkeeping, supervision, and fee-handling controls before their next examination.