Vigilant Compliance Newsletter

Published on Dec 2nd, 2025 |

Monthly Newsletter

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

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

Upcoming Filings:

12/01/25 – NFA CPO-PQR
12/05/25 – SEC Form 13G 10%
12/31/25 – DFSA Invoice
12/31/25 – DFSA Economic Substance Notification
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:

12/02/25 – New York Stock Exchange
12/04/25 – Investor Advisory Committee
12/04/25 – Closed Meeting
12/15/25 – Crypto Task Force Roundtable on Financial Surveillance and Privacy
To see upcoming 2025 SEC Meetings and Public Appearances click HERE!

Vigilant Announcements:

Vigilant Wins Private Equity Compliance Services Award

For the first time, Vigilant was honored as the Compliance Service of the Year (Fund Domicile) by Private Equity Wire in their 2025 US Awards.
The Private Equity Wire US Awards spotlight top Private Equity Service Providers and Fund Managers across the industry.
For more on the award, click here.

Vigilant Insights:

Reg S-P Alert for Large Firms

As the Regulation S-P deadline approaches, Firms must remain aware of the new requirements they must comply with.
Vigilant provides important information on the new rule and how we can help Firms meet the new standards of Reg S-P.
Learn more here.

During the government shutdown, regulatory operations stalled and many Firms with undergoing SEC Examinations were left in uncertain positions.
In this article, Vigilant’s Chief Operating Officer, Chuck Martin, MBA, shared his perspective in Ignites on the shutdown and the opportunities it presented for Firms to review and improve their compliance programs.
To read Chuck’s insights, click here.

Vigilant’s President & CEO, Salvatore Faia, Esq., CPA, CFE, participated on a Thompson Hine Webinar with Andy Davalla (Partner) and Shelbie Harvey (Senior Managing Associate).
This Webinar explored the continued growth of RIA mergers and acquisitions, what drives deal activity, and how Firms can structure transactions effectively. The Webinar covered areas including Regulatory and Compliance, Valuation Drivers, Deal Structures, and more.
Watch the Webinar Replay here.

Fund Boards are increasingly reevaluating the volume and relevance of their Annual 15(c) Materials, working to eliminate redundant or obsolete information, streamline lengthy questionnaires, and rely more on dashboard-style tools to navigate the hundreds of pages typically involved in the review process.
Recent industry developments, such as the rise of active ETFs for example, are shifting SEC priorities around fees and costs, and workflow changes that emerged during the pandemic have accelerated efforts to simplify 15(c) Materials.
Our President & CEO, Salvatore Faia, Esq., CPA, CFE, recently shared his insights on 15(c) Reporting with Fund Directions (a With Intelligence publication).
Click here to see Salvatore’s Insights on 15(c) Reporting.

SEC Releases:

On November 17, 2025, the SEC’s Division of Examinations (EXAMS) released its Fiscal Year 2026 Examination Priorities. These priorities provide a forward-looking roadmap of the areas in which the SEC plans to focus its examination resources, signaling risk themes and regulatory attention across RIAs, RICs, and Broker Dealers.
While many of the core risk areas remain consistent, the 2026 priorities reflect some evolution in emphasis, particularly around new Rules, technological risk, and operational resilience, underscoring how Firms should continue to adapt their compliance programs.
For more information on the 2026 Examination Priorities, click here.

On November 17, 2025, the SEC announced charges against six (6) Investment Advisory Entities for submitting Form ADV Filings that allegedly contained false information, misleading claims, and unverified business details.
Form ADV serves as the primary disclosure document used by Investment Advisers to register with the SEC and provide transparency regarding their operations, structure, and assets.
Read more here.

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