Vigilant Compliance Newsletter | June 2026
Monthly Newsletter
In June, there were important releases including Industry Events, Vigilant Insights and SEC Releases.
Below is a brief overview of what took place in the month of June, and what is approaching for July.
Events & Public Appearances by Officials
- 07/09/26 – Closed Meeting
- 07/13/26 – Rethinking the Rulebook: Modernizing the IPO Process and Access to Public Capital
- 07/21/26 – Small Business Capital Formation Advisory Committee Meeting
- To see upcoming 2026 SEC Meetings and Public Appearances click HERE!
Materials
Industry Events:
SEC 2026 Compliance Outreach Programs: Key Takeaways for RIAs and RICs
- In May and June 2026, the SEC hosted virtual Compliance Outreach Program Regional Seminars for Investment Advisers and Investment Companies in Atlanta and New York.
- The programs provided insight into examination priorities, common deficiencies, Regulation S-P (“Reg S-P”) implementation, fiduciary obligations, Private Fund examinations, and compliance program expectations.
- For key takeaways on these events, click here.
Vigilant Insights:
The Reg S-P Deadline Has Passed | Is Your Firm Ready?
- As of June 3, 2026, RIAs with less than $1.5 Billion in Assets Under Management (AUM) are now required to comply with the SEC’s amended Regulation S-P (“Reg S-P”) requirements. Larger entities over $1.5 Billion in AUM were already subject to the amendments on December 3, 2025.
- Vigilant Director, Laura Arnott, CFA, CIPM, IACCP®, CTPRP, CRISC, was recently quoted in Financial Advisor IQ providing her insights pertaining to Reg S-P.
- More on Laura’s Insights here.
SEC Risk Alert Reveals Common Billing and Disclosure Deficiencies
- The SEC recently issued a Risk Alert highlighting deficiencies identified during examinations of Investment Advisers related to fee billing practices, compensation arrangements, and conflicts of interest disclosures.
- Vigilant Chief Operating Officer, Chuck Martin, MBA, shared his insights with Financial Advisor IQ regarding the SEC’s Risk Alert.
- Click here for more on the SEC’s Risk Alert and Chuck’s Insights.
SEC Releases:
SEC Enforcement Alert: personal Trading and Compliance Lapses Lead to $1.5 Million Settlement
- On June 8, 2026, the SEC announced settled charges against an RIA and its former CEO arising from alleged breaches of fiduciary duty, undisclosed conflicts of interest, personal trading activity, and compliance program deficiencies.
- The SEC’s settlement included more than $1.5 Million (nearly $1.4 Million to the RIA and $181k to the former CEO) in combined disgorgement, prejudgment interest, and civil penalties.
- More information here.
Custody Rule and Annual Audit Failures Lead to $75,000 SEC Penalty
- The SEC announced settled administrative proceedings against a $1.4 Billion ($22.3 Million in Pooled Investment Vehicles) RIA that served as the investment adviser to multiple Private Funds for violations of the Investment Advisers Act Custody Rule.
- The SEC found that the Adviser failed to comply with the Custody Rule by neither obtaining the required annual audits nor satisfying the alternative custody safeguards for multiple fiscal years.
- Learn more about the violations here.
The Vigilant Team is always happy to schedule a time to chat, feel free to contact us with any questions!
