News & Analysis as of

Form ADV Registered Investment Advisors

Eversheds Sutherland (US) LLP

SEC Proposes Significant Changes To “Small Business” And “Small Organization” Definitions

Proposed amendments would significantly expand small entity thresholds and introduce automatic inflation adjustments. On January 7, 2026, the US Securities and Exchange Commission (SEC) proposed amendments (Proposal) to...more

Adams & Reese

SEC Proposes to Modernize "Small Entity" Definitions for Funds and Advisers

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What you need to do: Identify whether your fund family is at or below ~$10 billion in aggregate net assets and whether your advisory business is under $1 billion regulatory assets under management (“RAUM”); confirm Form N-CEN...more

Mayer Brown

SEC Staff Publishes New Marketing Rule FAQs

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On January 15, 2026, the staff of the Division of Investment Management (the “staff”) of the Securities and Exchange Commission (the “SEC”) updated its Marketing Compliance-Frequently Asked Questions (“FAQs”) to include two...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

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

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

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

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

Kilpatrick

More Screen Time: SEC Adopts Amendments to Internet-Only Investment Adviser Exemption

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On March 27, 2024, the Securities and Exchange Commission (“SEC”) announced amendments to the rule that allows internet-only investment advisers to register with the SEC (the “Rule”). The amended Rule eliminates the current...more

Quarles & Brady LLP

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

Quarles & Brady LLP on

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

Dorsey & Whitney LLP

2024 SEC Examination Priorities for Investment Advisers

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The SEC’s Division of Examinations (the “Division”) announced its examination priorities for fiscal year 2024. This eUpdate includes observations on the examination priorities and a list of examination priorities that impact...more

Lowenstein Sandler LLP

Slew of Recent SEC Enforcement Actions: Guidance for Registered Investment Advisers

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On September 5, the U.S. Securities and Exchange Commission (SEC) announced enforcement actions against five investment advisers for violating Rule 206(4)-2 (the Custody Rule) and Rule 204-1(a) (the ADV Reporting Rule) of the...more

Tannenbaum Helpern Syracuse & Hirschtritt LLP

SEC’s Recent Enforcement Sweeps Targeting Off-Channel Communications of Fund Advisers

In this time of continuing digital transformation, the use of smartphones and messaging apps, such as WhatsApp, Signal, iMessage, Facebook Messenger, WeChat, and Telegram, has become increasingly popular in business practice....more

Stinson LLP

SEC Proposes Enhanced Safeguarding (Custody) Rule for Registered Investment Advisers

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On February 15, 2023, the U.S. Securities and Exchange Commission (SEC) proposed to exercise its authority by amending and re-designating Rule 206(4)-2 under the Investment Advisers Act of 1940 (the Custody Rule)....more

Tannenbaum Helpern Syracuse & Hirschtritt LLP

How the SEC’s Proposed New Safeguarding Rule May Impact Private Fund Advisers

On February 15, 2023, the U.S. Securities and Exchange Commission (“SEC”) issued a proposed rule (the “Proposal”) under the Investment Advisers Act of 1940 (the “Advisers Act”), which would (i) amend certain provisions of the...more

Quarles & Brady LLP

Annual Update of Form ADV and Recent Regulatory Changes Affecting Advisers

Quarles & Brady LLP on

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

Cooley LLP

SEC Proposes New Rule and Record-Keeping Requirements for Outsourcing by Registered Investment Advisers

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Engaging service providers and outsourcing various functions is a normal part of running an effective business. From the newest emerging managers to the most established ones, venture capital firms and private fund shops...more

Faegre Drinker Biddle & Reath LLP

SEC Proposes ESG Disclosure Requirements for Investment Advisers

In a three-to-one vote on May 25, 2022, the U.S. Securities and Exchange Commission (SEC) issued proposed amendments to rules and reporting forms that would require registered investment advisers — including private fund...more

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