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:
Recent 2026 SEC examination priorities continue to focus on fee billing accuracy, compensation disclosures, and fiduciary obligations. Examiners are placing particular emphasis on:
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.
One of the most overlooked - and most important - compliance activities is recurring fee testing.
The SEC commonly requests sample account reviews during examinations, including:
Without centralized controls and documented testing procedures, even small billing inconsistencies can quickly become larger regulatory concerns.
Firms should consider implementing:
Strong operational infrastructure is no longer just about efficiency; it is part of demonstrating fiduciary responsibility.
The SEC is also increasing scrutiny around undisclosed compensation and conflicts of interest, paying heightened attention to:
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:
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:
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:
Proactive firms are implementing:
Protecting senior clients is not only good compliance practice, it’s central to maintaining the trust clients place in their advisory relationships.
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.