Check out our Flash Reports for the latest SEC- and compliance-related news, trends, and insights.
The SEC issued a final order that adjusts the dollar amount thresholds for “qualified clients” under Rule 205-3 of the Investment Advisers Act.
Read More
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.
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 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.