Vigilant Compliance Newsletter | April 2026
Monthly Newsletter
In April, there were important releases including Vigilant Events, Vigilant Announcements, Vigilant Insights and SEC Releases.
Below is a brief overview of what took place in the month of April, and what is approaching for May.
Events & Public Appearances by Officials
- 05/04/26 – Milken Institute Global Conference 2026
- 05/07/26 – 13th Annual Conference on Financial Market Regulation
- 05/08/26 – AI+ Expo
- 05/12/26 – 2026 Compliance Outreach Program Regional Seminar for Investment Advisers and Investment Companies (Atlanta)
- To see upcoming 2026 SEC Meetings and Public Appearances click HERE!
Materials
Vigilant Events:
Reg S-P Webinar | Vigilant Events
- Vigilant will be participating in a co-hosted webinar with it’s affiliated Cybersecurity Firm, SilverPillar Cyber Advisors, as well as Stradley Ronon, Stevens & Young, LLP, and Morgan, Lewis & Bockius LLP.
- This webinar will provide practical guidance on the SEC’s amended Regulation S-P, with a focus on how firms can prepare for upcoming compliance deadlines and navigate evolving regulatory expectations.
- More information on how to register here.
Vigilant Announcements:
Vigilant Recognized as Finalist for Private Fund Compliance Award
- Vigilant is thrilled to announce that we have been shortlisted as the Best Compliance and Regulatory Adviser (Private Fund Industry) in Regulatory Compliance by The Drawdown for their 2026 Awards.
- Learn more about the Award Shortlisting here.
Vigilant Insights:
- So far in 2026, both the SEC and FINRA are reinforcing a familiar message, Firms must demonstrate (not just document) effective compliance programs.
- Q1 2026 reflects a continuation of core regulatory themes such as fiduciary duty, investor protection, and operational resilience, while also introducing heightened scrutiny around emerging risks like AI, cybersecurity, and data privacy.
- Click here for our coverage of compliance trends we have seen in Q1 2026.
- AI is quickly becoming part of how RIAs operate, whether through Portfolio Management tools, client communications, trading analytics, or compliance monitoring systems.
- While AI can improve efficiency and insights, it also introduces regulatory considerations under the SEC’s compliance framework.
- If you want to read more on AI Compliance Considerations for RIAs, click here.
When Do RIAs Consider an OCCO? | 5 Scenarios
- Due to evolving regulatory expectations, many RIAs are reassessing whether maintaining an in-house CCO is the most effective model.
- An Outsourced Chief Compliance Officer (“OCCO”) is not just a cost decision, it is often a strategic one that supports scalability, continuity, and regulatory alignment.
- More information here.
SEC Releases:
- The SEC’s Fiscal Year 2025 enforcement results signal a meaningful shift in how the agency approaches enforcement.
- While overall enforcement activity declined compared to the prior year, the SEC emphasized that this reflects a deliberate recalibration, prioritizing cases with clear investor harm, fraud, and market integrity over volume-driven or novel legal theories.
- Key takeaways from the SEC’s FY25 Enforcement Results here.
SEC & CFTC Propose Form PF Changes to Reduce Private Fund Reporting Burdens
- The SEC and CFTC jointly proposed amendments to Form PF aimed at reducing reporting burdens for Private Fund Advisers while still preserving regulators’ ability to monitor systemic risk.
- Click here to read more.
News and Alerts:
DOL Proposes New Fiduciary Framework for 401(k) Investment Selection
- The U.S. Department of Labor’s (DOL) proposed rule on “Fiduciary Duties in Selecting Designated Investment Alternatives” seeks to clarify how fiduciaries should evaluate and select investment options in participant-directed retirement plans, such as 401(k)s.
- Vigilant’s takeaways here.
The Vigilant Team is always happy to schedule a time to chat, feel free to contact us with any questions!
