On September 14, 2026, the staff of the US Securities and Exchange Commission’s (“SEC” or “Commission”) Division of Examinations (the “Division”) issued a Risk Alert (the “Risk Alert”) setting out their examination observations of SEC-registered investment advisers’ (“RIAs”) annual compliance reviews, as required by Rule 206(4)-7 (the “Compliance Rule”) under the Investment Advisers Act of 1940 (the “Advisers Act”). The Compliance Rule requires RIAs to, among other things, adopt and implement written compliance policies and procedures (the “Compliance Program”), and review the Compliance Program annually for effectiveness as further described below. The staff’s observations address the timeliness and completeness of those reviews, the consistency of the reviews with the RIAs’ written procedures, whether the reviews evaluated if the RIA’s current Compliance Programs continue to align with firm business practices and risks, proper retention of any documentation used in the reviews for books and records purposes, and the resolution of compliance matters identified during the reviews. The Risk Alert provides a useful indication of the particular areas examiners are likely to probe and underlines the SEC’s stated 2026 exam priority of focusing on the effectiveness of RIAs’ Compliance Programs.
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