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.
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.