Monthly Archives: October 2026

Compliance, Enforcement, Regulatory, Standard of Care

SEC Releases 2027 Examination Priorities: Is Your Compliance Program Ready?

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The SEC’s FY 2027 examination priorities send investment advisers a clear message: compliance programs must reflect how firms actually operate. Examiners will focus on:

  • Conflicts of interest: Fees, compensation, and whether practices match disclosures.
  • Private funds: Illiquid assets, allocations, borrowing, and fee and expense practices.
  • Compliance programs: Especially at firms with recent acquisitions, growth, or new strategies.
  • AI, cybersecurity, and vendors: Technology disclosures and third-party access to client data.
  • Proxy and reporting: Proxy adviser oversight and beneficial ownership filings.

Never-examined and newly registered advisers remain a priority. CCOs should use this roadmap to find gaps before examiners do. To help you make sense of what this means for you and your clients, read the full article from our friends at SEC3 here.

Compliance, Enforcement, International, Regulatory, Standard of Care

Updates on SEC, FINRA, FCA and more from FiSolve

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AI takes center stage in this edition, as regulators on both sides of the Atlantic push firms to innovate responsibly. We also cover a Supreme Court petition challenging FINRA, a cooling job market, new cross-border cooperation, and a major crypto enforcement action:

  • The SEC’s Brian Daly urges advisers not to wait for guidance before adopting AI, and outlines a “responsible retailization” initiative
  • A broker asks the Supreme Court whether constitutional challenges to FINRA proceedings must first go through the SEC
  • Hiring slows as the labor market cools, which may ease recruiting pressure in compliance and risk roles
  • The SEC will host a November 9 roundtable on machine-understandable data and super intelligence
  • The FCA calls for responsible AI adoption as finance moves toward an “agentic” future
  • The SEC and France’s AMF sign a supervisory MOU covering cross-border investment firms
  • Ireland’s central bank fines Coinbase Ireland €3.25 million for safeguarding and outsourcing failures

Read the full update from FiSolve here.

Regulatory, Standard of Care

SEC Proposes Expanded Performance Fee Eligibility and Accredited Investor Qualifications

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On September 30, 2026, the SEC proposed amendments to Advisers Act Rule 205-3 that would broaden when advisers may charge performance-based compensation. Separately, the SEC is weighing new ways for individuals to qualify as accredited investors. Key points:

  • One eligibility standard: The “qualified client” definition would adopt the Regulation D accredited investor standard, replacing separate net worth and AUM tests. This is a notable shift for 3(c)(1) funds and separately managed accounts.
  • Registered funds and BDCs: Could pay performance fees, subject to board approval and added disclosure.
  • New accredited investor pathways: The SEC is seeking comment on qualifying CPAs, CFAs, CFPs, and certain FINRA registrants, plus a possible FINRA-administered exam.

Until any changes take effect, current requirements still apply. In the meantime, advisers should review eligibility procedures, offering documents, and fee arrangements. Comments on the performance-compensation proposal are due December 7, 2026.

To help you make sense of what this means for you and your clients, read the full article from our friends at SEC3 here.