News & Insights: Jeremy McCamic

Jeremy leads the Policy Management team, which is responsible for staying current with regulatory changes and how they impact the firm’s investment adviser clients.

3 Key Compliance Predictions for 2026

2026 will be one of constant changes for the SEC and regulatory professionals. As you surf these waves of change, here are three key predictions for Compliance Programs in 2026 to help keep you afloat.

SEC Adds Two New Marketing Rule FAQs

On January 15, 2026, the SEC updated its Marketing Rule FAQ with new guidance for model performance and disqualifying events for compensated promoters giving testimonials or endorsements.

CFTC No-Action Relief from Commodity Pool Operator Registration for Private Fund Managers

On December 19, 2025, the Commodity Futures Trading Commission’s Market Participants Division (“MPD”) announced a no-action letter stating the MPD will not recommend the CFTC initiate an enforcement action against firms registered as investment advisers with the SEC, who operate commodity pools privately offered solely to sophisticated investors known as qualified eligible persons (“QEPs”), for failing to register as a commodity pool operator, subject to certain conditions.

SEC Risk Alert: Marketing Rule Violations for Testimonials, Endorsements, and Third-Party Ratings

the SEC Division of Examinations published the first risk alert of 2025. The risk alert provides additional information on compliance with the Marketing Rule.

Regulation S-P Enforcement Action and SEC Outreach on Amended Regulation S-P

The SEC recently published settled charges against a dual-registrant for compliance failures under the prior version of Regulation S-P.

Form SHO Deadline Approaches: Will It Be Delayed Again?

The first Form SHO filing was set to be due on Valentine’s Day 2025, but the SEC pushed back the deadline to February 17, 2026. Now, as large entities finalize Reg S-P preparations, and as all compliance programs complete annual IARD renewals, the question for 2026 is: will Form SHO be delayed again?

2026 Examination Priorities Published by SEC Division of Exams

On November 17, 2025, the SEC’s Division of Examinations (“EXAMS”) published its 2026 Examination Priorities. The SEC’s fiscal year runs from October 1st to September 30th, and these annual priorities highlight practices and products viewed by EXAMS as presenting heightened risks to investors and the markets overall.

SEC Reopens: What to Expect After the Shutdown

The longest government shutdown in U.S. History officially ended on November 12th. Government employees are back at work, and the SEC has reopened. However, it may take time for the SEC to return to normal operations.

IARD Annual Renewal: Preliminary Statements Are Live

Despite the government shutdown, IARD renewal deadlines are live, and renewal payments are still due. 

Custody Relief for Crypto Assets: SEC No-Action Letter Benefits Advisers and Registered Investment Companies

On September 30th, the SEC Division of Investment Management gave an answer to the most challenging question for crypto assets: What entities are qualified custodians for crypto assets? Since qualified custodians must meet the definition of a banking institution for both the Adviser Act’s Custody Rule and the Investment Company Act’s.

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