For Registered Investment Advisers (RIAs) with a December 31 fiscal year-end, April
2026 is a critical post-filing month focused on client delivery, private fund reporting, and
preparing for upcoming cybersecurity mandates.
Key Deadlines: April 2026
- Early April: Large traders file Form 13H amendments, and Large Liquidity Fund Advisers File Form PF.
- April 15: Advisers to ERISA plans should provide compensation and service disclosures, assisting clients with upcoming Form 5500 filings.
- April 30: Deadline to deliver updated Form ADV Part 2A to clients.
- April 30: Annual Form PF updates are due for private fund advisers with $150M in RAUM, and audited financial statements must be delivered to investors for those utilizing the custody rule exemption.
Regulatory Watchlist and Emerging Priorities
Regulation S-P: Smaller RIAs (under $1.5B AUM) must prepare for the June 3, 2026, compliance deadline for incident response and service provider oversight.
Definitions & Rules: The SEC is reviewing a proposal to raise the "small entity"
threshold to $1 billion in assets, while the effective date for new Investment Adviser
AML/CFT rules is proposed to be delayed until January 1, 2028.
Examination Focus for 2026
The SEC's Division of Examinations is prioritizing "operational effectiveness", with focus areas including:
- AI and Marketing: Scrutiny of "AI washing" in disclosures and compliance with the Marketing Rule regarding testimonials and performance.
- Fiduciary Duty: A demand for more specific, non-boilerplate conflict disclosures.
