The Compliance Platform Imperative: Why Investment Managers Can't Afford to Wing It

Kioko, J. (2026, May 1). The Compliance Platform Imperative: Why Investment Managers Can't Afford to Wing It. Leo RegTech. https://leo.tech/us/the-compliance-platform-imperative-why-investment-managers-cant-afford-to-wing-it/

• The SEC's Division of Examinations released its fiscal year 2026 examination priorities in November 2025, applying to investment advisers, investment companies, broker-dealers, and other registrants.

• Under Chair Paul Atkins, examination and enforcement resources are being redirected toward fraud and concrete investor harm, while retail investor protection, RIA fiduciary obligations, and the effectiveness of RIA compliance programs remain priorities.

• The 2026 priorities highlight core elements of RIA compliance programs including marketing, valuation, trading, portfolio management, disclosure and filings, and custody, alongside emerging risks such as cybersecurity, due diligence, and Regulation S-P compliance.

• Examiners will evaluate whether firms' actual AI usage matches their representations to clients and regulators, and firms claiming to use AI for portfolio management must demonstrate that the tools genuinely influence investment decisions rather than serve as supplemental research.

• The amended Regulation S-P requires incident response planning and data breach notification, with firms over $1.5 billion in AUM required to comply from December 3, 2025, and smaller firms by June 3, 2026.

• Required Regulation S-P documentation includes the incident response program and its updates, risk assessments and evaluations of data security controls, incident logs, and vendor oversight records, all of which must be available on short notice for SEC examinations.

• In December 2025 the CFTC issued a no-action letter permitting many SEC-registered private fund managers to opt out of registering as commodity pool operators and commodity trading advisors, addressing concerns about duplicative registration for pools offered exclusively to sophisticated investors.

Knote: We usually don't publish writeups from vendors talking about the problems that their product solves, but this one seemed refreshingly balanced.