News & Analysis as of

Form ADV

Seward & Kissel LLP

SEC Delegates Authority to the Director of the Division of Investment Management in Connection with Confidential Information...

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On December 29, 2025, the Securities and Exchange Commission (the “SEC”), through a rule amendment,1 delegated authority to the Director of the Division of Investment Management to authorize the issuance of orders to grant,...more

Proskauer Rose LLP

SEC Permits Confidential Treatment Requests for Form ADV Information

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On December 29, 2025, the Securities and Exchange Commission (the “SEC”) issued a final rule delegating authority to the Director (the “IM Director”) of the Division of Investment Management (“IM”) to grant, deny, and revoke...more

Foley Hoag LLP

Reminder: Renewal and Notice Filing Fees for Investment Advisers Due by December 8

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As a reminder, investment advisers who are subject to any state registration, renewal or notice filing fees must have funded their IARD accounts by December 8, 2025 in order to cover such fees (with a recommendation from IARD...more

Stark & Stark

[Hybrid Event] RIA Compliance and Legal Strategies Conference - December 4th, Hamilton Township, NJ

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The RIA Compliance and Legal Strategies Conference is back at our offices in Hamilton, NJ. The Conference is an essential event for RIAs and IARs to gain a valuable understanding of current regulatory and compliance-related...more

Morrison & Foerster LLP

AI Compliance Tips for Advisers

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As artificial intelligence (AI) systems such as ChatGPT and other generative tools gain traction across the financial services industry, investment advisers are increasingly exploring ways to leverage AI in their operations....more

Proskauer - Regulatory & Compliance

SEC Guidance on the Government Shutdown

As of 12:01 am on October 1, 2025, congressionally appropriated funding lapsed for most operations of the United States government. Though the government has shut down, business continues, and market participants that need to...more

Seward & Kissel LLP

Latest Disclosure Trends in the Form ADV Brochure

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Stay ahead of the curve with Seward & Kissel’s analysis of Form ADV Part 2A (“Brochure”) filings from leading SEC-registered investment advisers...more

Akin Gump Strauss Hauer & Feld LLP

Atkins-Led SEC Brings First Enforcement Action for Compliance Failures Under the Marketing Rule

On September 4, 2025, the U.S. Securities and Exchange Commission (SEC) brought its first enforcement action under the Marketing Rule since Chair Paul Atkins was sworn in earlier this year—charging Meridian Financial, LLC...more

Holland & Knight LLP

SEC Feels the Heat

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Earlier this year, the U.S. Court of Appeals for the First Circuit vacated and remanded a $93 million district court judgment entered against a broker-dealer and investment adviser for allegedly inadequate disclosures of...more

SEC Compliance Consultants, Inc. (SEC³)

Top Compliance Program Mistakes (and How to Avoid Them) (Part 2 of 2)

As discussed in our prior article, it's important to have a well-built foundation for your compliance program. But creating the program is just the start of the journey. Compliance is a journey requiring adaptation,...more

Troutman Pepper Locke

FUNDamentals: Form N-PX — Institutional Investment Managers Must File, Even if No ‎Proxies Were Voted

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With Form ADV annual updating amendments due for many investment advisers by the end of next month, advisers should consider whether to update their proxy voting policies and related disclosure in Part 2A, Item 17 in light of...more

SEC Compliance Consultants, Inc. (SEC³)

The Most Wonderful Time of the Year: Form ADV Season

For most investment advisers, March signals the beginning of Form ADV season, where compliance officers gather all kinds of firm data to update a document fraught with potential regulatory liability. For the uninitiated, Form...more

Foley Hoag LLP

Important Dates and Reminders for Investment Advisers, Exempt Reporting Advisers, Commodity Trading Advisors and Commodity Pool...

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INVESTMENT ADVISERS - Annual Compliance Reviews - All investment advisers registered with the Securities and Exchange Commission (“SEC”) or at the state level are required to review their compliance policies and...more

Quarles & Brady LLP

Annual Update of Form ADV and Recent Regulatory Changes Affecting Advisers (UPDATED)

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As a reminder, each registered investment adviser must file an annual updating amendment to its Form ADV within 90 days of its fiscal year end. This means an adviser with a December 31 fiscal year end will be required to file...more

BCLP

SEC Enforcement Actions for Failure to File Form D: A Wake-up Call for Startups and Private Fund Advisers

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On December 20, 2024, the U.S. Securities and Exchange Commission (the “SEC”) issued a press release highlighting settled enforcement actions against a private fund adviser and two pre-IPO companies for failure to timely file...more

Latham & Watkins LLP

SEC Targets Investment Advisers for Misstatements and Compliance Failures

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Three recent enforcement actions highlight the risks of failing to adhere to representations made to investors regarding ESG and biblically responsible investing strategies....more

Goodwin

SEC Sends Additional Message to Registered Investment Advisers on Marketing Rule Obligations Through Enforcement Actions

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On September 9, 2024, approximately one year since its first flurry of similar Marketing Rule actions, the Securities and Exchange Commission (the SEC) announced settlements with nine SEC-registered investment advisers (the...more

Tannenbaum Helpern Syracuse & Hirschtritt LLP

Are Entities in Your Private Fund Structure Reportable under FinCEN’s Beneficial Ownership Regulation?

As of January 1, 2024, the Beneficial Ownership Information Reporting Requirements (the “Reporting Rule”) issued by Financial Crimes Enforcement Network (“FinCEN”) to implement Section 6403 of the Corporate Transparency Act...more

Herbert Smith Freehills Kramer

SEC and FinCEN Propose Rule Requiring Investment Advisers to Enact Customer Identification Programs

On May 13, 2024, the Securities and Exchange Commission (SEC) and the Financial Crimes Enforcement Network (FinCEN) of the U.S. Treasury Department announced a joint notice of proposed rulemaking that would require investment...more

Vedder Price

SEC Staff's Latest Marketing Rule Risk Alert Highlights Initial Observations from Examinations

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On April 17, 2024, the SEC’s Division of Examinations issued its latest risk alert regarding Rule 206(4)-1 of the Investment Advisers Act of 1940, known as the Marketing Rule. Following the examinations staff’s June 2023 and...more

Tannenbaum Helpern Syracuse & Hirschtritt LLP

SEC Division of Examinations Publishes Marketing Rule Risk Alert

The staff of SEC’s Division of Examinations (the “Staff”) recently issued a Risk Alert (the “Alert”) outlining the Staff’s initial observations from sweep exams conducted to assess SEC registered investment advisers’ (“RIAs”)...more

Royer Cooper Cohen Braunfeld LLC

The New Marketing Rule: Notes from the Field

On April 17th, the SEC issued a Risk Alert titled “Initial Observations Regarding Advisers Act Marketing Rule Compliance.” Perusing the list of failures, a sense of familiarity arose, given that one of our clients had been...more

BCLP

SEC Risk Alert on Compliance with the Marketing Rule-Examination Observations

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On April 17, 2024, the Division of Examinations (the “Division”) of the Securities and Exchange Commission (the “SEC”) published a Risk Alert entitled: “Initial Observations Regarding Advisers Act Marketing Rule Compliance”...more

Dinsmore & Shohl LLP

SEC Division of Examinations Risk Alert: Initial Observations Regarding Advisers Act Marketing Rule Compliance

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On April 17, 2024 the Securities and Exchange Commission (“SEC”) Division of Examinations (the “Division”) issued a Risk Alert regarding investment advisers’ compliance with amended Investment Advisers Act Rule 206(4)-1 (the...more

Goodwin

The SEC Amends the Internet Adviser Exemption

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On March 27, 2024, the US Securities and Exchange Commission (SEC) adopted amendments to Rule 203A-2(e) of the Investment Advisers Act of 1940 (the Advisers Act) (the Internet Adviser Exemption)....more

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