SEC Regulatory Updates

Stay informed with the latest SEC rulemaking, guidance documents, enforcement actions, and staff statements affecting registered investment advisors.

Staff GuidanceJanuary 15, 2026

SEC Staff Publishes New Marketing Rule FAQs on Model Fees and Promoter Disqualifications

The SEC Division of Investment Management added two new FAQs clarifying that Footnote 590 is not prescriptive regarding model vs. actual fees in performance advertising, and providing conditions under which advisers may compensate promoters subject to SRO final orders.

Risk AlertDecember 16, 2025

SEC Issues Risk Alert: Additional Observations on Marketing Rule Compliance

The only risk alert of 2025 focuses on testimonial/endorsement disclosure failures and third-party rating compensation disclosures. Common deficiencies include missing promoter disclosures, absent written agreements, and undisclosed compensation for ratings.

EnforcementFebruary 20, 2025

SEC Continues Marketing Rule Enforcement Focus

The SEC Division of Enforcement continues targeted examinations of investment advisor compliance with the Marketing Rule (Rule 206(4)-1), with particular focus on testimonials, performance advertising, and third-party ratings disclosures.

GuidanceJanuary 30, 2025

SEC Announces 2025 Examination Priorities Including AI and Cybersecurity

The SEC Division of Examinations released its 2025 examination priorities, highlighting AI use in advisory services, cybersecurity practices, and Marketing Rule compliance as key focus areas for investment adviser examinations.

RulemakingJune 15, 2025

SEC Withdraws Proposed Safeguarding Rule (Custody Modernization)

The SEC formally withdrew its February 2023 proposed Safeguarding Rule, which would have modernized custody requirements. The SEC indicated it would take a more targeted approach to custody rule modernization going forward.

EnforcementAugust 14, 2024

SEC Off-Channel Communication Penalties Exceed $560M in 2024

The SEC charged more than 60 firms with recordkeeping failures related to off-channel communications in 2024, with penalties exceeding $560 million for the year. Cumulative penalties since December 2021 surpass $3 billion.

Staff StatementsOctober 28, 2024

SEC Staff Statement on ESG Fund Disclosures

SEC Division of Investment Management staff issued a statement providing expectations for ESG-focused fund disclosures, emphasizing the need for specificity in describing ESG strategies and voting policies.

RulemakingDecember 3, 2025

Regulation S-P Compliance Deadline: What Firms Must Have in Place Now

As of December 3, 2025, larger entities must comply with amended Reg S-P requirements including incident response programs, 30-day breach notification, service provider 72-hour notification agreements, and enhanced information security safeguards. Smaller entities have until June 3, 2026.

RulemakingMay 16, 2024

SEC Adopts Amendments to Regulation S-P for Data Breach Notification

The SEC adopted the first major update to Regulation S-P since 2000, requiring incident response programs, 30-day breach notification, service provider oversight with 72-hour notification, and enhanced information security safeguards.

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