News & Insights

Check out our Flash Reports for the latest SEC- and compliance-related news, trends, and insights.

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.

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SEC Proposes Change of RFA Small Business Threshold

On January 7, 2026, the SEC proposed amendments to the rules defining small entities for purposes of the Regulatory Flexibility Act (“RFA”).

FinCEN Takes Final Step to Postpone AML/CFT Rule

The Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a final rulemaking to extend the effective date of the AML/CFT Rule until January 1, 2028.

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.

SEC Order Delays Form SHO Deadline to 2028

On December 3, 2025, the SEC issued an order providing an exemption from compliance with the short position and short activity reporting rules. According to the order, compliance with Rule 13f-2 and Form SHO is now delayed until January 2, 2028.

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?

The Countdown is on: Time to Comply with Amended Reg S-P

The compliance deadline for larger advisers (those with $1.5B or more in AUM) is less than two weeks away (Dec. 3, 2025). While much of what the previous administration proposed has been tossed or postponed, the SEC has made it clear that Amended Reg S-P is not only here to stay, but it’s also a key focus area.

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.

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