Vigilant Compliance Newsletter

Published on Oct 1st, 2025 |

Monthly Newsletter

In September, there were important releases including Vigilant Insights and SEC Releases.

Below is a brief overview of what took place in the month of September, and what is approaching for October.

Upcoming Filings:

10/07/25 – SEC Form 13G 10%
10/10/25 – SEC Form 13H Quarterly
10/15/25 – SEC Form PF Liquidity Fund Quarterly
10/30/25 – AIFMD Annex IV
10/30/25 – FSRA Annual PIB
To stay up to date with the SEC Filing Deadlines in 2025, click here to view Vigilant’s Compliance Calendar.

Events & Public Appearances by Officials:

10/15/25 – DC Fintech Week 2025
10/17/25 – Crypto Task Force Roundtable on Financial Surveillance and Privacy
To see upcoming 2025 SEC Meetings and Public Appearances click HERE!

Vigilant Insights:

Vigilant discusses the potential benefits that an Outsourced PFO can provide Registered Investment Companies and their Boards.
With today’s Registered Fund landscape, obligations and expectations of PFOs have grown exponentially, resulting in demands that often exceed the capacity of a traditional in-house finance team.
More on how an Outsourced PFO can support Registered Funds here.

The SEC’s Investor Advisory Committee (IAC) recently issued recommendations to expand retail investor access to alternative investments through registered vehicles. These developments could reshape the landscape of Private Markets.
Vigilant Director, Bill Speacht, provided his insights on FundFire on the potential benefits of this regulatory shift.
View Bill’s insights here.

SEC Releases:

Marketing Rule & Recordkeeping Violations | RIA Charged

On September 4, 2025, the SEC issued an administrative order against a $258 Million RIA for multiple compliance violations.
The RIA paid a $75,000 civil penalty for infringing on regulations related to the SEC’s Marketing Rule, recordkeeping obligations, compliance policy implementation, and conducting an annual compliance review.
Read more here.

On September 18, 2025, the SEC announced a $5 Million Civil Penalty against a well-known Broker/Dealer for misrepresenting the accuracy and speed of its U.S. options market data.
The Broker/Dealer made materially misleading statements regarding the speed and accuracy of its market data, highlighting the critical importance of truthful communication and the need for robust compliance monitoring.
For further details, click here.

On August 29, 2025, the SEC ordered a well-known Adviser to pay a fine of $19.5 Million.
The SEC cited failures in disclosing conflicts of interest and deficient internal controls involving their Personal Advisor Services program.
Learn more about the findings here.

On August 29, 2025, the SEC charged an RIA over $5 Million and its affiliated Broker/Dealer $750,000.
The charges were due to failing to adequately disclose conflicts of interest to Retirement Plan Participants regarding their Managed Account Service.
Click here for more information about the charges.

On September 4, 2025, SEC Commissioner, Mark Uyeda, spoke at the SIFMA Private Markets Valuation Roundtable.
Uyeda highlighted the vital role that Private Capital Markets play in fueling economic growth, job creation, and innovation, emphasizing that Private and Public Markets are complimentary, not competitive.
For key takeaways on the Commissioner’s thoughts on Private Capital Markets, click here.

The Vigilant Team is always happy to schedule a time to chat, feel free to contact us with any questions!