Periodic analysis of SEC, FINRA, FinCEN, OFAC, and cross-border regulatory developments affecting the institutions we serve.
On September 15, 2026, the SEC approved FINRA Rule 3290, consolidating Rules 3270 and 3280 into a single rule governing registered persons' outside activities. The details now matter for firms updating their policies.
The SEC's Division of Examinations has published a Risk Alert on one of the most fundamental, and most frequently cited, compliance obligations for investment advisers: the annual compliance review under Rule 206(4)-7.
On September 16, 2026, the SEC approved a FINRA proposal consolidating Rules 3270 and 3280 into Rule 3290, reshaping how broker-dealers oversee registered representatives' outside business activities after nearly a decade of debate.
In a proposal issued September 3, 2026, the SEC would rescind Advisers Act Rule 206(4)-5, which currently bars investment advisers from providing compensated advisory services to government clients for two years following certain political contributions.
In a proposal issued January 7, 2026, the SEC would raise the asset thresholds used to define 'small entities' from $25 million to $1 billion in AUM for RIAs, and from $50 million to $10 billion in net assets for investment companies.
On July 16, 2026, the SEC proposed Regulation E-Delivery, which would allow issuers, broker-dealers, investment advisers, and other market participants to satisfy many federal securities law delivery requirements electronically, without first obtaining affirmative investor consent.
The SEC has proposed rescinding its 2024 climate-related disclosure rules, which would have required public companies to provide standardized information regarding climate-related risks, governance, and certain climate-related financial impacts.
The Executive Order directs federal agencies to review and potentially strengthen AML, KYC, CIP, sanctions screening, beneficial ownership, and customer due diligence requirements. Firms are not yet required to act, but should monitor closely as regulators issue guidance.
FINRA proposed reforms to modernize and streamline its enforcement process, following the SEC's broader push toward faster, more transparent investigations. The enforcement process itself is becoming a compliance risk area.
FINRA recently outlined updated identity verification requirements for Entitlement Program accounts, reinforcing stronger controls around user access, authentication, and account administration.
On April 17, 2026, the SEC and CFTC jointly proposed amendments to Form PF to reduce private fund reporting burdens while refining key risk data collection. Less reporting, or just different reporting?
The SEC just tightened Regulation S-P. FINRA is now pointing firms to what actually changed and what needs to be in place: written incident response, breach detection and escalation, client notification, and vendor oversight.
On March 20, 2026, the SEC's Division of Enforcement announced updates to its Enforcement Manual, aligning investigations with digital communications, off-channel activity, and evolving cooperation standards.
RIAs and broker-dealers may offer similar services to clients, but they operate under very different regulatory regimes. For compliance teams, the differences in primary regulator, supervision, advertising, and recordkeeping are significant.
Florida-registered RIAs: submitting annual financial statements to the OFR follows a defined process through the REAL system — but small oversights can still create delays.
On January 7, 2026, the SEC proposed amendments to the definitions of small entities for registered investment advisers, investment companies, and BDCs under the Regulatory Flexibility Act.
FINRA proposed Rule 3290 (Outside Activities Requirements), which would replace existing Rules 3270 (Outside Business Activities) and 3280 (Private Securities Transactions), potentially reshaping compliance responsibilities and economics for hybrid models.
Most AML failures don't come from obvious fraud. They come from patterns firms normalize over time — until examiners don't. Here are the red flags RIAs and broker-dealers most often overlook.
The Division of Examinations' 2026 priorities continue its risk-based focus on investor protection, operational resiliency, and emerging technologies. Examinations will concentrate on AI, crypto, data security, AML, and T+1 settlement.
OFAC sanctions, FATCA reporting limits, and local banking instability have turned Venezuela into a high-risk jurisdiction for U.S. and cross-border advisers. Here's what RIAs and BDs need to get right.
The North American Securities Administrators Association released its 2025 Enforcement Report, covering 2024 data and showing a sharp rise in state-level action: over 8,800 investigations and 1,183 enforcement actions reported.
Training isn't optional for RIAs — it's proof of a living compliance program. But not all training requirements are created equal: IAR CE, annual compliance training for staff, and topic-specific sessions all play different roles.
Cyber threats don't care how big your firm is — they care how well you're protected. Too many RIAs still fail the same cybersecurity test the SEC keeps giving. Here are the five most common blind spots.
Most people approach the Series 65 like a college exam. It isn't one. It's a professional logic test — part memory, part judgement, part ethics. Passing is less about how much you know, and more about how you think like a fiduciary.
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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