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SEC Division of Examinations - Additional Observations Regarding Marketing Rule 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

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DCS Alert - SEC Order Grants Temporary Exemptive Relief from Form SHO

SEC Order Granting Temporary Exemptive Relief from Compliance with Rule 13f-2 and Form SHO

On December 3, 2025 the SEC issued an Order granting temporary exemptive relief from compliance with Rule 13f-2 and Form SHO.  Pursuant to Rule 13f-2 an “institutional investment manager” (which by definition includes investment advisers) is required to file Form SHO with

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SEC Division of Examinations - 2026 Examination Priorities

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,

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DCS Alert - FinCEN Postponement and Reopening of RIA AML Rule

FinCEN Announces Postponement and Reopening of the Investment Adviser Anti-Money Laundering Rule

On July 21, 2025 the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone the effective date of the final rule establishing the investment adviser anti-money laundering obligations – the IA AML Rule.  In the announcement,

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