Periodic analysis of SEC, FINRA, FinCEN, OFAC, and cross-border regulatory developments affecting the institutions we serve.
The SEC has proposed amendments that would revise small entity classifications under the Regulatory Flexibility Act for investment companies, investment advisers, and BDCs. Firms should review whether these changes affect their reporting and compliance obligations.
FINRA's proposed Rule 3290 addresses how registered investment adviser activities are classified and supervised within hybrid broker-dealer models. Dual registrants should assess potential operational and supervisory implications.
FinCEN has formally proposed postponing the investment adviser anti-money laundering rule effective date from January 2026 to January 2028. While the delay provides additional runway, firms are encouraged to continue program development.
Significant changes to the Qualified Business Income deduction and Section 1202 gains exclusions are reshaping tax planning considerations for financial institutions and their clients.
OFAC has designated the Cartel de los Soles as a terrorist organization. Firms with Venezuelan client exposures or cross-border activity should review their sanctions screening and EDD procedures.
FinCEN has announced a delay of the investment adviser compliance rule effective date. The window allows firms to strengthen program foundations before enforcement obligations take effect.
The SEC has resumed processing applications from Swiss financial institutions seeking registered investment adviser status. Firms with Swiss affiliates or cross-border consulting structures should assess registration implications.
FINRA has detailed proposed changes to its fee structure alongside SEC approval of Private Funds regulatory updates. Broker-dealers should review the potential operational and cost impact.
Cerulli research highlights significant consolidation trends among registered investment advisers. As M&A activity accelerates, compliance integration planning becomes a critical operational priority.
The SEC has identified artificial intelligence oversight as a key examination focus area for 2025. Firms using AI in investment processes, client communications, or compliance functions should assess their governance and disclosure frameworks.
ICS Insights
Periodic regulatory commentary.
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