Vigilant Compliance Newsletter | February 2025
Monthly Newsletter
In February, there were notable releases featuring both Vigilant Insights and SEC Releases content.
Below is a brief overview of what took place in the month of February, and what is approaching for March.
New Rules, Regulations and Guidance
Upcoming Filings:
- 03/03/25 – NFA CPO-PQR
- 03/03/25 – NFA Annual Exemption Affirmation
- 03/07/25 – SEC Form 13G 10%
- 03/31/25 – Annual Update of SEC Form ADV
- 03/31/25 – CFTC/NFA CPO Annual Report
- 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:
- 03/03/25 – 41st Annual NABE Economic Policy Conference
- 03/06/25 – Investment Adviser Compliance Conference
- 03/06/25 – Wall Street Journal CFO Network Summit
- 03/06/25 – Investor Advisory Committee
- 03/06/25 – Sunshine Act Notice Closed Meeting
- 03/10/25 – Institute of International Bankers 2025 Annual Washington Conference
- 03/27/25 – SEC Roundtable on Artificial Intelligence in the Financial Industry
- To see upcoming 2025 SEC Meetings and Public Appearances click HERE!
Materials
Vigilant Insights:
How to Navigate Private Fund Compliance in 2025
- Over the past year, there has been a heightened sense of awareness on Private Fund Compliance Programs.
- Due to the regulatory activity surrounding Private Funds, Vigilant provided key compliance tips for Private Fund Advisers.
- To learn more, click here.
Is Deepseek AI Safe to Use? | Chuck Martin Insights
- When the AI model, DeepSeek, was announced recently, investors reacted swiftly to a high-performance AI model with allegedly only $6 million in funding.
- Compliance officers often face difficulty striking a balance between nurturing a proactive compliance culture and allowing employees to fully benefit from available technological advantages.
- Vigilant’s Chief Operating Officer, Chuck Martin, MBA, provided his thoughts surrounding DeepSeek on Fundfire.
- Click here to view Chuck’s insights and more.
The Language of Expected Returns | Bernadette Murphy Insights
- Under the SEC’s Marketing Rule, firms are prohibited from advertising hypothetical performance unless it is for a targeted audience and all material information is disclosed relating to hypothetical performance.
- Vigilant Managing Director, Bernadette Murphy, MSL, was quoted in a Fundfire article providing insight into compliance concerns such language creates.
- Read more of Bernadette’s insights into this language here.
SEC Releases:
- The SEC charged a New York RIA $150,000, and one of its former Investment Advisors $75,000, for misconduct involving their retail clients.
- Fiduciary Duty requires Investment Advisers to consider the best interest of their clients, especially when there are significant conflicts of interest involved.
- Click here to read more about the charges.
SEC Announces Cyber and Emerging Technologies Unit (CETU)
- With Cybersecurity and Artificial Intelligence (AI) as top priorities for the SEC in 2025, the SEC announced on February 20th, 2025, the creation of the Cyber and Emerging Technologies Unit (CETU).
- The focus of this unit will be “combatting cyber-related misconduct and to protect retail investors from bad actors in the emerging technology space”.
- View the CETU’s Priorities and Vigilant’s conclusion, here.
The Vigilant Team is always happy to schedule a time to chat, feel free to contact us with any questions!
