The SEC recently announced two enforcement actions against advisory firms that failed to provide clear and consistent disclosures around conflicts of interest tied to fee-based managed account programs. Both cases underscore the Commission’s continuing focus on how financial incentives influence employee recommendations — and the need for firms to adopt policies and procedures that address disclosure risks.

Advisers and broker-dealers face heightened regulatory expectations around transparency. Compensation arrangements that create incentives for employees to recommend firm products must be disclosed accurately and consistently across Form ADV, Form CRS, websites, and client communications. Misaligned or contradictory disclosures not only erode client trust but also invite significant penalties. Read the full article from our friends at SEC³ here.

On August 15, 2025, the SEC charged a New York based private equity adviser with breaching its fiduciary duties under Section 206(2) of the Investment Advisers Act of 1940. The case centered on failures to properly disclose fee practices and to apply management fee offsets as required. The adviser agreed to resolve the matter, paying over $683,000 in disgorgement, penalties, and interest.

Read more here, including important compliance takeaways.