--- title: Regulatory Round-Up August 2026 description: RIAs should review compliance alignment, cybersecurity readiness, and third-party oversight ahead of SEC exams and Regulation S-P changes in 2026. image: https://blog.truewest-consulting.com/hubfs/TW-OctoberRoundUp.jpg --- [![TrueWest-WhiteLogo-Transparent](https://blog.truewest-consulting.com/hs-fs/hubfs/Branding/TrueWest-WhiteLogo-Transparent.png?width=2000&height=390&name=TrueWest-WhiteLogo-Transparent.png "TrueWest-WhiteLogo-Transparent")](https://truewest-consulting.com) [![TrueWest-WhiteLogo-Transparent](https://blog.truewest-consulting.com/hs-fs/hubfs/Branding/TrueWest-WhiteLogo-Transparent.png?width=2000&height=390&name=TrueWest-WhiteLogo-Transparent.png "TrueWest-WhiteLogo-Transparent")](https://truewest-consulting.com) - [About](https://www.truewest-consulting.com/about) - [Technology](https://www.truewest-consulting.com/technology) - [Services](https://www.truewest-consulting.com/services) - Compliance - [RIA Compliance](https://www.truewest-consulting.com/services/ria-compliance) - [Private Fund Compliance](https://www.truewest-consulting.com/services/private-fund-compliance) - [Legal](https://www.truewest-consulting.com/services/legal) - [IT Operations & Governance](https://www.truewest-consulting.com/services/it-operations-and-governance) - [Finance](https://www.truewest-consulting.com/services/finance) - [News & Insights](https://blog.truewest-consulting.com/news-insights) - [Contact](https://www.truewest-consulting.com/contact) [Tech Portal Login](https://truewest.greenboard.com/) [Schedule a Call](https://www.truewest-consulting.com/schedule-a-call) [Tech Portal Login](https://truewest.greenboard.com/) [Schedule a Call](https://www.truewest-consulting.com/schedule-a-call) - [About](https://www.truewest-consulting.com/about) - [Technology](https://www.truewest-consulting.com/technology) - [Services](https://www.truewest-consulting.com/services) - Compliance - [RIA Compliance](https://www.truewest-consulting.com/services/ria-compliance) - [Private Fund Compliance](https://www.truewest-consulting.com/services/private-fund-compliance) - [Legal](https://www.truewest-consulting.com/services/legal) - [IT Operations & Governance](https://www.truewest-consulting.com/services/it-operations-and-governance) - [Finance](https://www.truewest-consulting.com/services/finance) - [News & Insights](https://blog.truewest-consulting.com/news-insights) - [Contact](https://www.truewest-consulting.com/contact) [Tech Portal Login](https://truewest.greenboard.com/)[Schedule a Call](https://www.truewest-consulting.com/schedule-a-call) [Regulatory Round Up](https://blog.truewest-consulting.com/news-insights/tag/regulatory-round-up) # Regulatory Round-Up August 2026 [![True West](https://blog.truewest-consulting.com/hs-fs/hubfs/Branding/Graphics/TrueWest-Icon-In-Circle.png?width=40&height=40&name=TrueWest-Icon-In-Circle.png)](https://blog.truewest-consulting.com/news-insights/author/true-west) by [True West](https://blog.truewest-consulting.com/news-insights/author/true-west) Aug 06 2026 Regulatory Round-Up August 2026 2:33   ## **Staying Ahead of SEC Expectations: Key Compliance Updates for RIAs** As regulatory expectations continue to evolve, the SEC remains focused on one central question: **Can your firm demonstrate that its compliance program is working?** This month's Regulatory Round-Up highlights four areas every RIA should review, from compliance program testing and best execution to business continuity planning and new qualified client thresholds for firms charging performance-based fees. ### **1. Compliance Program Testing: Moving Beyond the Annual Checklist** Annual reviews have long been required under Rule 206(4)-7, but today's SEC examinations are looking for much more than evidence that a review occurred. Examiners want to see that firms are actively identifying risks, testing controls, documenting findings, and making meaningful improvements. Areas receiving heightened scrutiny include: - Marketing Rule compliance - Fiduciary obligations and conflict management - Custody controls - Cybersecurity and Regulation S-P preparedness - Vendor oversight - Valuation practices #### **What You Should Do** Rather than treating compliance testing as a once-a-year exercise, build a risk-based testing program that includes: - Regular testing of high-risk processes - Transaction sampling and walkthroughs - Gap analyses comparing practice to policy - Clear documentation of findings and remediation **Takeaway:** Your policies are only as strong as your ability to demonstrate they're working. ### **2. Best Execution Remains a Fiduciary Priority** Best execution continues to be a significant examination priority for RIAs. While many advisers associate best execution with commission costs, the SEC evaluates whether firms are seeking the most favorable overall outcome for clients - including execution quality, market impact, responsiveness, financial stability of broker-dealers, and overall value. Common examination deficiencies include: - Failure to perform documented broker reviews - Using a single broker without evaluation - Weak directed brokerage procedures - Inadequate documentation supporting broker selection #### **Recommended Actions** - Review your Best Execution Policy. - Conduct and document broker evaluations annually. - Verify Form ADV disclosures remain accurate. - Train investment and compliance personnel on current expectations. **Takeaway:** Best execution isn't a one-time decision—it's an ongoing fiduciary obligation. ### **3. Business Continuity Planning: Is Your Firm Ready?** Although the SEC doesn't prescribe a standalone Business Continuity Plan (BCP) rule for RIAs, operational resiliency remains a key examination focus. Your BCP should demonstrate that your firm can continue serving clients during events such as: - Cyberattacks - Natural disasters - Power outages - Loss of key personnel - Vendor disruptions The SEC also expects firms to regularly test these plans—not simply maintain them. #### **Key Review Areas** - Backup and recovery procedures - Cyber incident response integration - Key-person succession planning - Vendor contingency planning - Client communication procedures - Books and records accessibility **Takeaway:** A business continuity plan should be a living document that evolves with your firm's operations and risk profile. ### **4. Qualified Client Thresholds Increase Effective June 29, 2026** **For advisers managing private funds or charging performance-based fees**, new inflation-adjusted Qualified Client thresholds became effective June 29, 2026. The updated thresholds are: - **Assets Under Management:** $1.4 million (previously $1.1 million) - **Net Worth:** $2.7 million (previously $2.2 million) Existing advisory agreements are generally grandfathered, but new investors and advisory relationships entered after the effective date must satisfy the updated requirements. #### **Firms Should Consider** - Updating subscription documents - Revising advisory agreements - Reviewing pending investor closings - Updating compliance manuals and training materials **Takeaway:** Even routine inflation adjustments require careful document reviews to ensure ongoing compliance. ### **Final Thoughts** This month's updates reinforce a consistent theme across recent SEC examinations: regulators are increasingly focused on **how firms demonstrate compliance—not simply whether policies exist.** Whether it's testing compliance controls, documenting best execution reviews, strengthening business continuity planning, or updating client qualification procedures, firms that proactively review and refine their processes will be better positioned during examinations and better equipped to protect their clients. #### **How True West Can Help** True West partners with RIAs to build practical, exam-ready compliance programs that go beyond documentation. From annual compliance testing and best execution reviews to business continuity planning and regulatory updates, our team helps firms strengthen their compliance framework while allowing advisors to remain focused on serving clients. If you have questions about how these updates impact your firm, reach out to your True West consultant. We're here to help you navigate the regulatory landscape with confidence. [Stay compliant and proactive with your policies and procedures](https://www.truewest-consulting.com/schedule-a-call) ### Stay compliant and proactive with your policies and procedures For detailed guidance and tailored compliance tools, become a client and access our full monthly Regulatory Round-Up. 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All Rights Reserved. - [Privacy Policy](https://45187591.hs-sites.com/privacy-policy) ![Nancy_Headshot-min](https://blog.truewest-consulting.com/hs-fs/hubfs/Website%20Imagery/Headshots/Nancy_Headshot-min.jpg?width=1575&height=1575&name=Nancy_Headshot-min.jpg) ## Nancy Harry Founder Nancy is a founding Member at True West. She brings over 20 years of experience in the financial industry with a concentrated focus in regulatory compliance consulting for registered investment advisory firms. She has a passion for working with clients in developing their compliance programs and assists firms with building a true culture of compliance. Nancy strives to keep a simple and straightforward approach to running an efficient compliance program. [mailto:nancy.harry@truewest-consulting.com](mailto:nancy.harry@truewest-consulting.com) ![Kari_Headshot-min](https://blog.truewest-consulting.com/hs-fs/hubfs/Website%20Imagery/Headshots/Kari_Headshot-min.jpg?width=225&height=225&name=Kari_Headshot-min.jpg) ## Kari Thiessen Founder Kari is a founding Member at True West. She brings nearly 30 years of experience in the financial services industry with a history in regulatory tax compliance, tax planning, economics and supply chain consulting. Kari takes pride in developing practical and innovative solutions for clients. Kari brings a broad and deep set of skills for any business, corporate or single person shop. [mailto:kari.thiessen@truewest-consulting.com](mailto:kari.thiessen@truewest-consulting.com) ![SigridAlegri_TrueWest B&W-1](https://blog.truewest-consulting.com/hs-fs/hubfs/SigridAlegri_TrueWest%20B%26W-1.jpeg?width=1575&height=1575&name=SigridAlegri_TrueWest%20B%26W-1.jpeg) ## Sigrid Alegria Associate Sigrid is an Associate at True West Consulting, bringing with her nearly a decade of experience in the legal and compliance sectors. Her background includes roles as an in-house compliance associate, as well as experience with prominent firms such as Goldman Sachs & Co. Sigrid has developed a strong expertise in regulatory compliance, with a particular focus on evolving Registered Investment Advisor (RIA) regulations. At True West, she leverages her comprehensive knowledge to provide operational support to a diverse range of clients, helping them navigate complex compliance challenges and stay ahead of regulatory changes." [mailto:Trish.Gallagher@truewest-consulting.com](mailto:Trish.Gallagher@truewest-consulting.com) ![Caroline_Headshot-min](https://blog.truewest-consulting.com/hs-fs/hubfs/Website%20Imagery/Headshots/Caroline_Headshot-min.jpg?width=1575&height=1575&name=Caroline_Headshot-min.jpg) ## Caroline Iannucci Associate Caroline is a Compliance Associate at True West. Caroline brings with her 10 years of Wall Street experience and broad based knowledge of the financial markets. As an institutional equity salesperson, she covered both hedge funds and mutual funds, specializing in public equities and private stock offerings. [mailto:caroline.iannucci@truewest-consulting.com](mailto:caroline.iannucci@truewest-consulting.com) ![TrueWest-Headshot-Carliss-min](https://blog.truewest-consulting.com/hs-fs/hubfs/TrueWest-Headshot-Carliss-min.jpg?width=225&height=225&name=TrueWest-Headshot-Carliss-min.jpg) ## Carliss Marshall Associate Carliss is a Compliance Associate at True West Consulting with six plus years of compliance experience. She has worked both as a member of an in-house compliance team and as a compliance consultant responsible for multiple clients. Carliss has experience in a variety of compliance focus areas, with extensive experience in regulatory filings. She has worked with both registered and unregistered investment advisory firms, ensuring all aspects of their compliance programs run smoothly and all regulatory requirements are met.   [mailto:carliss.marshall@truewest-consulting.com](mailto:carliss.marshall@truewest-consulting.com) ![Sara_Sparks-min](https://blog.truewest-consulting.com/hs-fs/hubfs/Website%20Imagery/Headshots/Sara_Sparks-min.jpg?width=225&height=225&name=Sara_Sparks-min.jpg) ## Sara Sparks Consultant Sara is a seasoned Compliance Consultant at True West specializing in registered investment advisory firms. She offers guidance and best practices on constantly changing securities division regulations and ensures firms are prepared for regulatory examinations. Sara has experience with newly registered firms and well-established firms. She assists firms with developing and maintaining a robust compliance program through guidance of policies and procedures, risk assessments, and performing day-to-day compliance duties. [mailto:sara.sparks@truewest-consulting.com](mailto:sara.sparks@truewest-consulting.com) ![Tammy_Headshot-min](https://blog.truewest-consulting.com/hs-fs/hubfs/Website%20Imagery/Headshots/Tammy_Headshot-min.jpg?width=225&height=225&name=Tammy_Headshot-min.jpg) ## Tammy Steffen Associate As a Compliance Consultant/Associate with True West Consulting, Tammy brings 39 years of experience throughout the financial services industry. With extensive experience in compliance procedures and policies, operations, and supervision, Tammy has worked with Broker-Dealer, and Registered Advisory firms to bolster and enhance their operations and compliance programs. [mailto:tammy.steffen@truewest-consulting.com](mailto:tammy.steffen@truewest-consulting.com) ![HughSimpson_Headshot-2-min](https://blog.truewest-consulting.com/hs-fs/hubfs/Website%20Imagery/Headshots/HughSimpson_Headshot-2-min.jpg?width=225&height=225&name=HughSimpson_Headshot-2-min.jpg) ## Hugh Simpson Consultant Hugh Simpson is a skilled professional in the financial services industry, with a deep background in the areas of legal, compliance, internal audit, enterprise risk management, corporate governance and government relations. He recently completed a 33-year stint as Executive Vice President – General Counsel and Corporate Secretary of two significant Fort Worth-based financial services companies. Prior to that he was a partner in the Corporate and Securities Section of one of the oldest and largest law firms in Fort Worth. Hugh now consults on a variety of issues in the financial services space. He takes a sensible, solutions-oriented approach to risk management, promotes effective corporate governance, and upholds high ethical standards. [mailto:contact@truewest-consulting.com](mailto:contact@truewest-consulting.com) ![Aaron Payne - Headshot](https://blog.truewest-consulting.com/hs-fs/hubfs/Aaron%20Payne%20-%20Headshot.jpg?width=1575&height=1575&name=Aaron%20Payne%20-%20Headshot.jpg) ## Aaron Payne Consultant **Aaron Payne** is an IT Infrastructure and Cybersecurity specialist with deep experience leading technology transformation efforts within the financial services sector. In recent years, he has helped RIAs and FMOs modernize disjointed and outdated IT environments - bringing them into alignment with regulatory expectations and operational best practices. His work focuses on building secure, well-governed systems that support business growth, reduce risk, and hold up under regulatory and audit scrutiny. [mailto:deshaunne.kurulak@truewest-consulting.com](mailto:deshaunne.kurulak@truewest-consulting.com) ![David Lewien](https://blog.truewest-consulting.com/hs-fs/hubfs/David%20Lewien.jpg?width=1575&height=1575&name=David%20Lewien.jpg) ## David Lewien CEO - Go West IT David Lewien is the founder and CEO of Go West IT in Greenwood Village, Colorado. Founded in 2010, Go West IT is the security obsessed Managed Service Provider that expertly guides businesses to opportunity and protects them from harm in the digital frontier. [mailto:david.lewein@truewest-consulting.com](mailto:david.lewein@truewest-consulting.com) ![Mark Brown](https://blog.truewest-consulting.com/hs-fs/hubfs/Mark%20Brown.jpg?width=1575&height=1575&name=Mark%20Brown.jpg) ## Mark Brown Founder - Advisor Armor Mark Brown is the founder of Advisor Armor [mailto:deshaunne.kurulak@truewest-consulting.com](mailto:deshaunne.kurulak@truewest-consulting.com) ![Bridget-Katz](https://blog.truewest-consulting.com/hs-fs/hubfs/Website%20Imagery/Headshots/Bridget-Katz.jpeg?width=2400&height=2400&name=Bridget-Katz.jpeg) ## Bridget Katz  Project Manager and Onboarding Associate  As a Project Manager and Onboarding Associate with True West, Bridgetbrings over 20 years of extensive experience in the financial industry, specializing in serving large RIAs and their high-net-worth clients. In addition to serving RIAs, she led the onboarding advisor experience for a TAMP, demonstrating her expertise in streamlining client and advisor onboarding processes. Passionate about delivering end-to-end onboarding solutions, Bridget has successfully managed onboarding for multiple RIAs, supporting hundreds of users by ensuring seamless system access, compliance, and comprehensive training. Additionally, she has overseen client service operations, optimized systems, and aligned departmental efforts to ensure every client interaction reflects the highest standards of service. [mailto:bridget.katz@truewest-consulting.com](mailto:bridget.katz@truewest-consulting.com) ![Anna-Burdine](https://blog.truewest-consulting.com/hs-fs/hubfs/Website%20Imagery/Headshots/Anna-Burdine.jpeg?width=2400&height=2400&name=Anna-Burdine.jpeg) ## Anna Burdine Associate Anna is a Compliance Associate at True West Consulting with five years of compliance experience. She is an accomplished financial services professional with a strong background in compliance, supervision, and advisor support on the broker dealer side of business. Prior to her current role, she worked at LPL Financial as a supervisory principal on the advisor review team where she held her Series 7 and 24 licenses. Now with True West, she is excited to draw on her broad industry expertise as she transitions to supporting RIAs. 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