November 14, 2025
What happened?
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.
Filing Backlog
The EDGAR filing system was open during the shutdown and continued to accept new filings. These now await the SEC staff for processing and review. It will take several weeks for reviews and approvals to return to their pre-shutdown pace. The SEC Division of Corporation Finance published “Guidance After Government Shutdown” aimed at filings for issuers. This guidance indicated that SEC staff are “working expeditiously to clear the backlog of filings” and that staff “will continue to review those filings in the order in which they were received.” Although the guidance is not aimed at Registered Investment Advisers, the same activity is likely occurring across the commission.
Examination Teams Playing Catch-up
Firms whose SEC examination was interrupted by the shutdown are now seeing SEC examiners get back in touch. Examiner messages reiterate that it is going to take some time to get back up to speed. Lead examiners are also referencing a period of “reprioritizing” in these messages. Expect to see updates for any active examinations within the next few weeks.
What does this mean to me?
Compliance never stops. If you slowed down during the shutdown, you need to speed up with the reopening of the government. Be sure to check your email for responses from regulators and check any ZixMail accounts tied to open examinations. The regulators are back in the saddle, and compliance professionals should be too.
Filings and requests are now being reviewed, examination teams are getting back in touch, and the December 3rd deadline for Reg S-P is still live and nearly here for large entities. If you need assistance with your compliance program or guidance during this time, please let us know. Members of our team are available to help.
