What We’ve Learned From The SEC In 2025

September marked the end of the SEC’s fiscal year, and as we prepare to receive the SEC’s new priorities for the next fiscal year, I think it’s time to look back and see what we learned in the past twelve months to help predict what we will be seeing going forward.

We saw familiar faces return with Chair Paul Atkins leading the commission this year. We saw staff numbers decrease with DOGE cuts happening earlier in the year. However, while this slowed the rollout of new regulation, it did not slow enforcement actions, with the number of enforcement actions and examinations remaining consistent with previous years. We saw breaks from tradition with a former military judge being appointed as the new Director for the Division of Enforcement.

But what did that mean for firm owners?

Key Updates:

• A renewed interest in reducing client harm. This saw an increase in enforcement actions against Ponzi schemes, Insider Trading, and other types of fraud.
• Examinations remained steady, which means it is not the time to ignore your compliance requirements.
• Crypto-specific task forces have been established, resulting in increased public engagement around cryptocurrency and digital securities.

My Take:

We tend to see large changes within the SEC when a new administration comes into government; this year was no different. The SEC is still handing out deficiency notices, upholding examination targets, but giving some reprieve by extending mandatory compliance dates to allow firms to catch up with new regulation requirements. This doesn’t mean putting off your compliance until those dates are looming, it means doing the required testing to ensure that your firm is meeting its requirements before those dates. If you’d like some help knowing how to make sure you’re compliant, don’t be scared to reach out; the compliance nerds are here to help.

Ask Leila

Q: What are the most important compliance tasks to get on top of before the end of the year?

A:  Start with the basics.  A routine examination is going to request documents and information related to your foundational compliance requirements.  Make sure your client files are complete and up to date. Review your last few Annual Compliance reviews and reports and ensure deficiencies have been remediated.  If there are repeat deficiencies noted, prioritize fixing them.  You must be able to produce proof of delivery of Annual Amendments, CRS and other disclosures.Make sure you have read and understand your compliance manual.  You want to verify that what it states is consistent with your business practices and that you are actually following it. Regulators don’t like templates.  Make sure yours has been reviewed and customized to your business. Use this time to plan. Identify where improvements can be made and make a plan for getting them fixed. If you need additional resources, identify what those are- whether it’s personnel, technology or access to experts. Do your due diligence, identify your budget and set a timeline for implementation.  Even if you have issues to resolve, regulators will want to see that you have at least identified and implemented a plan to fix the. Work smart, not hard.

Responsible Entrepreneurs

“My RIA Lawyer’s Outsourced Compliance Department has been an incredibly valuable resource for our firm. Their team quickly understood our specific needs, provided expert compliance guidance, and helped us stay audit-ready with efficient testing procedures. They identified overlooked gaps and offered practical, tailored solutions. Their professionalism and responsiveness have saved us time and resources, allowing us to focus more on growth. We highly recommend them to any firm looking for reliable, knowledgeable compliance support.” Rich Dragotta, ChFC, AIF, CRPC

Want a compliance provider that doesn’t just give you consultative advice but does your compliance for you? Do you want a compliance provider that isn’t afraid to go toe-to-toe with the regulators to protect your firm? Do you want proactive rather than reactive compliance? There are two spots available to access our Done-For-You Outsourced Compliance Department solutions this October, and the results speak for themselves. Reply with “Outsource” if you’d like to find out more information about how our team of compliance nerds can help you out.

Snapshot

A new season is about to start for our Regulate This! Podcast. If you haven’t yet caught up on season two, then this episode might be a great place to start. With the end of the year looming it’s time to really think about what you want for yourself and your firm in 2026, and the ground work you put in now is going to make that process so much easier. Don’t forget to subscribe to our podcast on Youtube so that you never miss an episode.