Regulatory Round-Up January 2026

Happy New Year! As we step into 2026, now is the perfect time to ensure your firm is compliant, prepared, and confident. January is a critical moment to reflect, set priorities, and position your compliance program for the year ahead.

Why Compliance Matters More Than Ever

The SEC’s 2026 exam priorities signal a renewed focus on doing the fundamentals exceptionally well. Key areas to watch include:

• Disclosures: Keep Form ADV, agreements, and marketing materials accurate and consistent

• Conflicts of Interest: Identify, disclose, and actively manage conflicts

• Regulation S-P: Strengthen cybersecurity and client data protection

• Third-Party Oversight: Monitor vendors with access to firm or client data

• Marketing Rule: Apply requirements correctly, especially for performance and testimonials

Examiners will be closely evaluating the alignment between your written policies, disclosures, and actual practices—making preparation essential.

January Focus: ADV Annual Amendment

January is the ideal time to begin preparing your ADV Annual Amendment. Starting early helps avoid last-minute stress and ensures accuracy. Focus on:

• AUM: Confirm calculations and methodologies

• Consistency: Align Form ADV Parts 1 and 2 with internal records

• Review: Validate ownership, services, fees, and disclosures

• Material Changes: Document significant changes from 2025

Clear, well-supported AUM figures are especially critical for exam readiness.

Don’t Overlook SMS Compliance

If your firm uses text messaging with clients, those communications must comply with Regulation S-P. Our SMS Privacy Policy Template helps you document permitted use, data protections, and compliance controls—ensuring your practices are ready for SEC scrutiny.

Looking Ahead to 2026

We’re excited to support you throughout 2026 with practical tools, clear guidance, and the upcoming launch of HERDWARE - our new technology designed to help firms meet real-world regulatory expectations with confidence.

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Join our community of firms committed to compliance excellence and start 2026 strong.

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Happy New Year!