Regulatory Updates Third Quarter 2025 for SEC Registered Investment Advisers

Welcome to the concise briefing on the latest SEC and CFTC regulatory developments impacting registered investment advisers (RIAs). This quarter highlights extended compliance timelines, ongoing policy reviews, and notable updates. Below is a structured overview to help advisers stay informed and compliant.

What this Covers

This document provides a comprehensive update on third-quarter 2025 regulatory developments affecting SEC-registered investment advisers. Core topics include recent guidance on closed-end fund investments, Form PF compliance extensions, policy changes regarding mandatory arbitration clauses, approval for dual share-class mutual fund/ETF structures, coordinated SEC/CFTC statements on spot crypto trading, clarified custodian rules for crypto assets, and enforcement actions relating to marketing, books-and-records, and compliance reviews.

Practical Next Steps for Advisers

Review and update offering documents and risk disclosures to account for expanded permissible investment scopes in closed-end funds.
Defer budget and system upgrades related to Form PF reporting until compliance requirements are finalized.
Assess and disclose mandatory arbitration provisions in new offerings to clients, updating governance documents.
Prepare to evaluate suitability and operational processes for potential ETF share classes within mutual funds.
Enhance compliance and due diligence, particularly regarding crypto custody providers and disclosures tied to spot crypto assets.
Audit marketing materials and compliance manuals to meet substantiation standards and properly document marketing claims and annual policy reviews.

This regulatory update equips advisers and compliance professionals with actionable intelligence to respond to evolving regulatory priorities and enforcement trends.

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