Published on Feb 2nd, 2025 |

Vigilant Compliance Monthly Newsletter - January 2025

Monthly Newsletter

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In January, there were important releases that contained both Vigilant Insights and SEC Releases content. There was also a Vigilant Announcement regarding a recent Award Shortlisting.

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

New Rules, Regulations and Guidance

New Rules, Regulations and Guidance

Upcoming Filings:

  • 02/07/25 – SEC Form 13G 10%
  • 02/14/25 – AIFMD Annex IV – Fund of Funds
  • 02/14/25 – SEC Form 13F Quarterly
  • 02/14/25 – SEC Form 13G 5%
  • 02/14/25 – SEC Form 13H Annual
  • 02/14/25 – NFA Form CTA-PR
  • 02/14/25 – SEC Form SHO
  • 02/28/25 – SEC Form PF Large Hedge Fund Update
  • 02/28/25 – SEC Form PF Private Equity Fund Advisers Quarterly Event Reporting
  • 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:

Materials

Materials

Vigilant Announcements:

Vigilant Shortlisted for 2025 Fund Compliance Award

  • Vigilant has been shortlisted as Best Compliance Advisory Firm by With Intelligence for their 2025 Operations and Services Awards.
  • After winning the award in 2024, Vigilant hopes to repeat again in 2025!
  • To view the Award shortlist, click here.

Vigilant Insights:

SEC’s Anticipated Regulatory Outlook | Chuck Martin Insights

  • The SEC started off their Fiscal Year with a record number of enforcement actions.
  • Our Chief Operating Officer, Chuck Martin, MBA, provided his insights on FundFire in focusing on the enforcement action results throughout the last two (2) Presidencies and what he is projecting for the upcoming regulatory outlook.
  • To view Chuck’s insights, click here.

Disclosure Errors for Registered Funds | Liam Clarke Insights 

  • The SEC’s Investment Management Unit reported in January that many ETFs, Mutual Funds, and Money Market Funds had errors in their disclosures and are lacking required information.
  • Our Director, Liam Clarke, CPA, MA, provided his insights on FundFire surrounding this report that was released.
  • To read Liam’s commentary, click here.

Adapting to the New Regulatory Landscape | Chuck Martin Insights

  • The SEC recently announced a record number of enforcements for Q1 of Fiscal Year 2025. The announcement occurred in midst of an on-going industry discussion about how the SEC is expected to operate under a new administration.
  • Vigilant’s Chief Operating Officer, Chuck Martin, MBA, provided insights in Ignites discussing how CCOs can prepare for this potential “New Era” for the SEC.
  • Click here to view Chuck’s insights and learn more about what to expect.

SEC Releases:

  • On January 29th, 2025, the SEC and CFTC extended the compliance date for the amendments to Form PF that were adopted on February 8th, 2024.
  • The compliance date for these amendments, which was originally March 12th, 2025, has been extended to June 12th, 2025.
  • Click here to view important takeaways from this extension.
  • The SEC recently announced the results of their Enforcement Actions for the first quarter of their 2025 fiscal year. The number of Enforcement Actions is at its highest for the first quarter since at least 2000.
  • Learn more about the SEC’s Enforcement Actions and Vigilant’s Conclusion here.
  • The SEC continues to investigate and charge Firms that fail to meet regulatory requirements around recordkeeping.
  • On January 13, 2025, nine (9) Investment Advisers and three (3) Broker Dealers faced penalties totaling $63.1 Million for failing to preserve electronic communications of their employees.
  • To learn more about the charges and the importance of recordkeeping, click here.

Names Rule FAQ Released by the SEC

  • The SEC published an FAQ to answer certain industry questions surrounding the amendments to the Names Rule adopted in 2023.
  • The SEC adopted those amendments in September of 2023 with the goal of preventing misleading or deceptive Investment Fund Names.
  • To view the synopsis of the Names Rule FAQ, click here.
  • The SEC settled charges against two (2) Fund Managers and the Sole Owner for expenses charged to their Private Funds. The SEC stated that a breach of their fiduciary duty occurred.
  • These actions resulted in fines and penalties of approximately $250,000.
  • To learn more about what was discovered by the SEC, click here.
  • On January 13, 2025, charges were announced against an Alternative Asset Management Company for false and misleading cybersecurity disclosures.
  • Cybersecurity was a major examination topic for the SEC in 2024. The speed and accuracy of disclosure requirements after cybersecurity incidents continues to face a high standard.
  • To view the details behind this cybersecurity charge, click here.
  • Three (3) Firms were charged $430,000 in total on December 20th, 2024 for failing to timely file Form D for Unregistered Securities Offerings.
  • Learn more about what happened and view our final conclusion here.

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

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