The takeaway in 30 seconds: The current SEC has pulled back from pursuing recordkeeping failures as standalone enforcement cases, but that is a change in enforcement focus, not a relaxation of the […]
The SEC’s May 29 proposal to rescind the 2024 climate disclosure rules will generate a lot of commentary about what it means for corporate America. Most of it won’t be directly useful […]
Most compliance dashboards answer the wrong question. They show what has been done: tasks completed, attestations collected, and policies acknowledged. Clean numbers, green indicators, and a sense of progress. What an SEC […]
The first hire was careful. You walked them through the compliance program personally, collected everything you needed, made sure their outside accounts were registered for trade monitoring before their first day. The […]
By now most RIAs under $1.5 billion in AUM know the June 3 date exists. Fewer have spent time thinking carefully about what “compliant” actually means when an examiner walks in and […]
Most RIAs that receive deficiency letters after an SEC examination didn’t know they had a problem. That is not a defense. It is the pattern. The findings that show up most consistently […]
The compliance mistakes new RIAs make aren’t usually dramatic. Nobody misses a filing deadline on purpose or decides to skip the written supervisory procedures altogether. The failures are quieter than that. Assumptions […]
When the SEC examination notice arrives, most RIAs do the same thing: they stop everything else and start preparing. Two weeks of pulling files, reconstructing approval trails, chasing employees for documentation that […]
Every year the SEC publishes its enforcement results and every year most RIAs skim the headline numbers and move on. This year that’s a mistake. The FY2025 report, released April 7, 2026, […]