Regulatory Round-Up June 2026

June Compliance Priorities for RIAs: Advisory Fees, Form CRS & Protecting Senior Clients

As we move into the second half of 2026, SEC scrutiny around advisory fees, firm billing practices, compensation disclosures, Form CRS obligations, and elder financial exploitation continues to intensify. For RIAs, the message is clear: operational discipline and proactive compliance oversight are foundational to sustainable growth.

At True West, we believe strong compliance programs are a strategic advantage that protects firms, strengthens client trust, and creates operational clarity that allows advisors to focus on growth and relationships.

This month, we are highlighting three critical areas every RIA should revisit:

• Advisory fee billing and firm compensation reviews
• Form CRS compliance and delivery obligations
• Elder abuse prevention and senior client protections

Advisory Fee Billing Remains a Top SEC Priority

Recent 2026 SEC examination priorities continue to focus on fee billing accuracy, compensation disclosures, and fiduciary obligations. Examiners are placing particular emphasis on:

• Accurate fee calculations and allocations
• Billing practices involving illiquid assets
• Proper application of fee schedules and breakpoints
• Clear disclosure of advisory fees and compensation structures
• Documentation supporting calculations and expense allocations

Many of the same deficiencies identified in the SEC’s 2021 Risk Alert remain common findings today, including incorrect fee calculations, weak policies and procedures, and inadequate disclosures in Form ADV Part 2.

At True West, we consistently encourage firms to move beyond “check-the-box” compliance and implement repeatable operational controls that reduce risk before an SEC exam ever begins.

Why Ongoing Testing Matters

One of the most overlooked - and most important - compliance activities is recurring fee testing.

The SEC commonly requests sample account reviews during examinations, including:

• New accounts
• Legacy client accounts
• Closed accounts with prorated calculations
• Retirement accounts
• Trusts and household relationships
• Large cash positions
• Wrap accounts
• Multi-custodian relationships

Without centralized controls and documented testing procedures, even small billing inconsistencies can quickly become larger regulatory concerns.

Firms should consider implementing:

• Quarterly fee reconciliation reviews
• Centralized billing oversight
• Updated ADV and advisory agreement alignment reviews
• Consistent documentation standards
• Independent testing procedures

Strong operational infrastructure is no longer just about efficiency; it is part of demonstrating fiduciary responsibility.

Hidden Compensation and Conflict Disclosure Risks

The SEC is also increasing scrutiny around undisclosed compensation and conflicts of interest, paying heightened attention to:

• Revenue-sharing arrangements
• Solicitor and referral compensation
• Third-party payments
• Proprietary product incentives
• Non-traditional benefits or gifts

Even indirect compensation or non-cash benefits can create disclosure obligations if they could influence recommendations or create conflicts with client interests.

RIAs should ensure:

• All compensation arrangements are fully documented
• Supervised persons disclose outside compensation and benefits
• Form ADV and internal records remain consistent
• Compliance teams maintain centralized compensation tracking

Form CRS Is Still Under the Microscope

Form CRS continues to be a frequent source of examination deficiencies for SEC-registered RIAs serving retail investors. Many firms treat Form CRS as a static filing. Regulators increasingly expect it to function as a living client-facing disclosure document that evolves alongside the business.

Best practices include:

• Integrating CRS reviews into annual compliance testing
• Reviewing disclosures after service or fee changes
• Testing delivery procedures during mock exams
• Maintaining website posting consistency

Protecting Senior Clients Is a Fiduciary Responsibility

The rise in elder financial exploitation cases continues to place pressure on RIAs to strengthen safeguards for vulnerable clients.

A firm’s fiduciary duty extends beyond investment management. Advisors must remain vigilant for:

• Cognitive decline
• Suspicious withdrawal activity
• Third-party influence
• Fraud and scam attempts
• Behavioral changes or unusual requests

Proactive firms are implementing:

• Trusted contact procedures
• Enhanced supervision for unusual transactions
• Ongoing client and family education
• Senior client interaction protocols
• Escalation procedures for potential financial exploitation

Protecting senior clients is not only good compliance practice, it’s central to maintaining the trust clients place in their advisory relationships.

Final Thoughts

The firms that navigate today’s regulatory environment most successfully are not simply responding to exams. They are building operational foundations designed for long-term resilience and growth.

Fee billing accuracy, transparent disclosures, Form CRS oversight, and elder client protections are all interconnected pieces of a broader compliance strategy rooted in accountability, documentation, and operational clarity.

At True West, we believe independence should never mean navigating these challenges alone.

Because strong compliance programs do more than reduce risk — they create the freedom to grow with confidence.