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.
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?
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.
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.
On September 4, 2025, the SEC issued an administrative order (“the order”) against a registered investment adviser (“RIA”) for compliance violations related to the Marketing Rule and the Books and Records Rule, among others. The RIA agreed to pay $75,000 in civil penalties for the violations.
On August 25, 2025, the Fifth U.S. Circuit Court of Appeals remanded two rules adopted during the Biden administration, giving hedge fund associations a partial victory. The rules were not vacated. However, the Securities and Exchange Commission (“SEC”) must now review them in light of the court’s opinion.
On August 25, 2025, the Fifth U.S. Circuit Court of Appeals remanded two rules adopted during the Biden administration, giving hedge fund associations a partial victory. The rules were not vacated. However, the Securities and Exchange Commission (“SEC”) must now review them in light of the court’s opinion.
On July 11, 2025, the SEC announced settled charges against a registered investment adviser (“RIA”), its CCO, and its president for creating backdated documents and producing them during an SEC examination; failing to adequately disclose conflicts of interest; and overbilling client accounts.