Regulatory Forum

With the holidays approaching, it’s a great time for investment advisers to revisit regulatory expectations regarding gifts and entertainment. Check out this quick video for key reminders on thresholds, documentation, and staying compliant through year-end.

Observations From 2025 & What to Look For in 2026

Join Morgan Lewis and Standish Compliance for a timely webinar discussing the SEC Examination and Enforcement Updates. The panel—including speakers from Morgan Lewis, Standish Compliance, and industry guest, Annie Hancock, Chief Compliance Officer and Deputy General Counsel at Altimeter and recent former attorney with the SEC’s Division of Enforcement—will discuss the SEC’s latest examination and enforcement priorities, trends observed throughout 2025, and key areas expected to shape the 2026 regulatory landscape.

Topics will include:

• Compliance with Regulation S-P
• Oversight of service providers
• Supervision and marketing of AI-driven strategies
• Exam trends and data analytics
• Enforcement themes emerging from recent SEC activity

DATE & TIME
Tuesday, December 2, 2025
1:00–2:00 pm ET

SPEAKERS
Christine Ayako Schleppegrell
Partner, Morgan Lewis

Annie Hancock
Chief Compliance Officer and General Counsel, Altimeter

Nicole De La Roca
Managing Director, Standish Compliance

Maryellen Maurer
Managing Director, Standish Compliance

ACCREDITATION
CLE credit in CA, FL, IL, MN, NY*, OH, OR, PA, TX, and VA is currently pending approval.

Credit in CT and NJ is pending approval via reciprocity. CLE credit is not available for the viewing of recorded sessions.

*This program qualifies for Newly Admitted Attorneys.

Those seeking CLE credit in any other state may be provided with a General Certificate of Attendance and may apply independently.

QUESTIONS?
Please contact Presley Valenzuela.

After registering for this event, you will receive webcast log-in instructions (or dial-in instructions for audio-only participation).

On November 17, 2025, the SEC Division of Examinations published its 2026 Examination Priorities. The leadership highlights that the U.S. capital markets are undergoing significant evolution, driven by product innovation, economic and geopolitical developments, as well as changes within the SEC itself. These forces require the Division to refine its approach to examinations while staying grounded in its core mission: promoting compliance, preventing fraud, informing policy, and monitoring risk. The SEC is reevaluating their risk-based priorities and how they approach various trends in the markets, new and emerging products and services, and their processes to ensure examinations continue to be efficient and effective.

Standish comment: Notably, the 2026 priorities did not have nearly the same emphasis on private fund regulation, which is a stark departure from prior years. The limited references to private funds, with only four direct mentions in the whole document, only pertain to newly launched private funds, private fund advisers who also manage separately managed accounts, and advisers that have not previously advised private funds.

The following are highlights of priorities that will mostly directly impact Standish Compliance clients.

• Adherence to Fiduciary Standards of Conduct
• Effectiveness of Investment Advisers’ Compliance Programs
• Never-Examined Advisers and Recently Registered Advisers
• Risk Areas
  • Information Security and Operational Resiliency
    • Cybersecurity
    • Regulation S-ID and Regulation S-P
  • Emerging Technology

Hearing a lot about AI lately?

If you’re wondering how to actually use it as an investment adviser — and stay compliant while doing so — we’ve got you covered.

Check out the video to see where to start!

We hope you were able to join Willkie Farr & Gallagher LLP and Standish Compliance for a timely and practical discussion on how investment advisers can prepare for and respond to the evolving landscape of cybersecurity and artificial intelligence risks. Topics included SEC focus areas and updates, emerging risks, practical tips, and tools for managing heightened risk and regulatory focus. The discussion was moderated by Andy Green, Senior Adviser, Standish Compliance. Panelists included: A. Kristina Littman, Partner, Willkie Farr & Gallagher LLP; Jennifer Porter, Partner, Willkie Farr & Gallagher LLP; and Alison Osburn, Chief Regulatory Counsel & Senior Compliance Officer, Standish Compliance.

If you would like a copy of the slides or a link to the recording, please contact us at info@standishcompliance.com.

September 30 marked the end of the SEC's fiscal year and the last day before the federal government shutdown. Q3 included notable developments and announcements by the SEC including, among others: 1) the appointment of new Directors of the Divisions of Enforcement and Corporation Finance; 2) a new Cross-Border Task Force; 3) a new era of collaboration between the SEC and CFTC; 4) a new Artificial Intelligence (AI) Task Force and AI examination initiative; 5) continued activities by the Crypto Task Force with a renewed vision at modernizing regulations as part of "Project Crypto;" 6) numerous new enforcement actions, focused on traditional areas such as disclosure fraud, insider trading and market manipulation, and breaches of duties by registrants; and 7) the dismissal of a number of active enforcement investigations, particularly those involving technical, non-fraud violations and relatively novel legal theories.

Most enforcement investigative and examination activity has been effectively halted during the government shutdown, as only essential activities are conducted during this period. This has resulted in a pause for ongoing examinations and will likely result in a delay in initiating new exams and completing open exams. However, we expect these activities to resume to their normal course once the shutdown is resolved. While there have been many indications of the priority shift under the leadership of Chairman Atkins, there may be a delay in publishing the 2026 Examination Priorities (which were published in October for the prior two fiscal years). The Standish Compliance team continues to track and analyze regulatory developments and their impact on our private fund and other clients. Let us know if you have questions regarding any regulatory developments or their application to your firm.