Compliance Risk Concepts

10/14/2026

On October 1, 2026, the SEC proposed the most consequential rewrite of its custody rules since 2009. Most of the early attention has gone to crypto, and understandably so.

But the part of this release that will touch the most firms has nothing to do with blockchains. It deals with standing letters of authorization, discretionary trading authority, inadvertent custody, private fund audits and surprise exams.

Comments are due December 7, 2026.

The SEC's proposed Rule 223-1 would rewrite the adviser and fund custody rules and add crypto custody paths. What changes, what stays and how to prepare.

10/13/2026

💬 : Personal Trading

Personal trading by access persons must be monitored and reported. Under Rule 204A-1, access persons report their holdings and transactions so the firm can review their trades against client activity.

10/08/2026

Every outlook this season will observe that enforcement is down. What changed in 2026 is that the rhetoric became rulemaking, and it did so across four regulators.

Read individually, each is relief. Read together, they describe a single transaction being made across the entire regulatory perimeter: a prescriptive instruction is being exchanged for a principles-based framework. That is not a reduction in work, it is a relocation.

Download CRC-Oyster's 2026-2027 Regulatory Round Up and Outlook: https://info.crcoyster.com/2027-regulatory-outlook

10/06/2026

: Form PF for Q3 is due Thursday, October 15.

10/02/2026

On September 28, 2026, the SEC's Chief Accountant and Director of the Division of Investment Management issued a joint statement on fair value measurement and disclosure considerations for private assets.

Private credit investments held in registered fund portfolios increased nearly 60% between December 2020 and December 2025. The statement creates no new requirements, but limited information does not excuse an unreliable valuation process.

10/01/2026

An advisor-matching RIA has agreed to pay a $450,000 civil penalty to settle SEC charges that it failed to disclose a conflict of interest to current and prospective clients.

From January 2023 to December 2024, the firm stood to gain when the clients it referred went to advisers using its own wealth platform, and it did not disclose that conflict.

Salespeople at the firm often went beyond the matching algorithm to recommend network advisors on its Zoe Wealth platform, according to the regulator.

09/29/2026

On September 14, 2026, the SEC's Division of Examinations published a Risk Alert on investment adviser annual compliance reviews. It proposes no new theory, addresses no new technology, and signals no new rule.

What it is telling the industry is that examiners may be viewing the state of a firm's compliance program through the lens of its annual compliance program review.

09/25/2026

💬 : Record Retention

Record retention requires preserving records for specified periods. Under Rule 204-2, this includes electronic communications and instant messages on approved platforms, which must be archived and accessible for five years.

09/24/2026

The CFTC/NFA regulatory framework is technically demanding, actively enforced, and distinct from the SEC/FINRA world.

CRC-Oyster delivers specialized NFA and CFTC compliance expertise across the full range of registrant types, from registration category analysis and exemption management through ongoing compliance program management and NFA examination support.

Visit our website to learn more about the Institutions We Serve: https://crcoyster.com/institutions/nfa-cftc-registered-firms/

09/23/2026

🚨 : Form 13H quarterly updates for Q3 are due Saturday, October 10.