Vigilant Compliance Newsletter

Published on Nov 4th, 2026 |

Monthly Newsletter

In October, there were important releases including SEC Releases and Vigilant Announcements.

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

Vigilant Announcements:

Vigilant Named Five-Time Hedgeweek Award Winner

For the fifth year in a row, Vigilant was awarded as the Regulatory & Compliance Firm of the Year by Hedgeweek for their 2026 US Awards.
The Hedgeweek US Awards conducted an online pool of the entire Hedgeweek userbase, where participants were asked to make their choice among the shortlisted firms in each category. The service provider categories span all the key areas of the broader Hedge Fund industry ecosystem.
For more on the Award, click here.

SEC Releases:

SEC Publishes New Examination Handbook

The SEC Division of Examinations (“EXAMS”) published a new SEC Exam Handbook.
According to the SEC, the Handbook provides a clear roadmap of the examination process used by Division examiners across the country to help promote consistency. The Handbook addresses the examination process from start to finish, including what EXAMS expects from Registrants and what Registrants can expect from EXAMS.
More information on the SEC’s New Examination Handbook here.

On September 30, 2026, the SEC proposed Amendments intended to expand retail investor access to Private Market Investments and modernize Regulated Fund structures.
The proposals address performance-based compensation for Investment Advisers, Interval Fund repurchases, and multiple Share Classes for certain Closed End Funds and BDCs.
Click here to learn more.

The SEC announced settled charges ($450,000) against an RIA that operated a service matching individuals with Third-Party Investment Advisers.
The SEC found that the Firm failed to adequately disclose financial incentives that could influence its referrals and misleadingly described how it managed certain conflicts of interest.
More details here.

The SEC announced a settled enforcement action against a New York-based Investment Adviser that managed four investment funds and its senior executive, who served as President, CEO, and Chief Compliance Officer.
The SEC alleged failures involving financial reporting, asset valuations, and investor communications. The settlement included permanent injunctions, a $200,000 civil penalty, and the appointment of a receiver to liquidate fund assets and distribute the proceeds to investors.
Key takeaways here.

On September 18, 2026, SEC Division of Enforcement Director, David Woodcock, delivered remarks outlining the Division’s enforcement priorities and recent initiatives.
The remarks emphasized a return to core enforcement objectives, including protecting investors, addressing misconduct that causes genuine harm, holding individual wrongdoers accountable, and returning money to harmed investors.
To read more on the SEC’s Enforcement Priorities, click here.

On October 23, 2026, the SEC’s Division of Examinations (“Division”) released its Fiscal Year 2027 Examination Priorities.
The FY 2027 priorities continue several areas of focus from prior years, but also placed additional emphasis on areas reflecting changes in products, business practices, and technology, including economic conflicts of interest, difficult-to-trade and illiquid investments, Private Credit, Third-Party Service Providers, super intelligence (“SI”), and evolving market infrastructure.
Learn more here.

On September 28, 2026, Chief Accountant, Kurt Hohl, and Director – Division of Investment Management, Brian Daly, issued a statement highlighting valuation and disclosure considerations for Private Assets, particularly Private Credit.
The statement emphasizes the importance of using appropriate valuation methods, considering current market conditions, and providing investors with clear information about asset valuations, portfolio risks, and related uncertainties.
Continue reading here.

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