Rule 206(4)-7 under the Investment Advisers Act of 1940 (the “Act”) requires SEC registered investment advisers to adopt and implement written compliance policies and procedures. As a component of Rule 206(4)-7, investment advisers are required to conduct a review of their compliance
The SEC Division of Examinations’ Additional Observations Regarding Advisers’ Compliance with the Advisers Act Marketing Rule
The SEC Division of Examinations issued a Risk Alert on December 16, 2025, providing the Division’s observations regarding advisers’ compliance with the Testimonials and Endorsements Provisions and Third-Party Ratings Provisions of the Marketing Rule. Specifically, the Division addresses observations regarding the satisfaction
Division of Examinations: SEC Fiscal Year 2026 Examination Priorities for Investment Advisers
On November 17, 2025, the Division of Examinations of the United States Securities & Exchange Commission (the “Division”) published the Fiscal Year 2026 Examination Priorities. In addition to investment advisers, the Division has examination responsibility for broker-dealers, investment companies, self-regulatory organizations, clearing agencies,
Summary of Regulation S-P Revisions Applicable to Investment Advisers
On May 15, 2024 the SEC issued Release Nos. 34-100155; IA-6604 (the “Adopting Release”) providing for amendments to the safeguards and disposal rules of Regulation S-P (the “Amendments”). The compliance dates for the Amendments are December 31, 2025 for “large” investment advisers
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