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It is important for investment managers and other investment management professionals to review the array of regulatory requirements they are obligated to fulfill.
We hope that this Regulatory and Compliance Calendar and accompanying materials will be a useful tool for managing compliance requirements throughout the year.
Regulatory & Compliance Calendar and Guidebook 2026
In assessing your 2026 compliance strategy, it is important to keep in mind not only individual requirements and best practices, but also the larger themes defining the regulatory and enforcement environment. Investment managers should review these themes in light of operational and compliance challenges they have faced and how they have modified their compliance programs to adapt to these changes. In our view, the SEC continues to send four clear messages:
- Transparency is a priority. The SEC is quick to act in cases where there is a lack of required disclosure or a conflict of interest, and in cases where an investment manager made a material misrepresentation. Firms should endeavor to be scrupulously transparent in their arrangements and transactions.
- Policies and procedures are just the start. Firms need to have a solid infrastructure that translates policies and procedures into actions and behaviors. This includes controls, internal audit functions, and appropriate and timely escalation protocols. Moreover, firms must act on and follow policies and procedures in a way that reasonably ensures compliance with such policies and procedures and applicable law.
- Compliance needs to be approached holistically. Compliance procedures cannot be applied in a check-the-box fashion. Firms must implement a risk-based approach driven by thorough due diligence of clients, employees, and vendors.
- All investment advisers are fiduciaries. Under the Advisers Act, all investment advisers are fiduciaries. Generally, investment advisers owe their clients a fiduciary duty comprised of the duty of care and the duty of loyalty. The SEC views an investment adviser's fiduciary duty as important to its investor protection efforts. All investment advisers, regardless of whether they are registered with the SEC (or otherwise exempt from registration), should conduct all their activities in a manner that takes into account their fiduciary duties to clients.
Investment managers that follow a rigorous application of regulatory requirements while keeping an eye on big-picture trends will be wellpositioned to avoid both the tangible and intangible costs that come with compliance shortfalls.
We look forward to working with you in the year ahead.
SECTION 1
REGULATORY AND COMPLIANCE CALENDAR
A FEW NOTES ON THE REGULATORY AND COMPLIANCE CALENDAR
This Regulatory and Compliance Calendar covers certain regulatory requirements applicable to all investment managers (including SEC-Registered Managers, Exempt Reporting Advisers, CPOs, and CTAs) and private funds. It does not cover CPO obligations with respect to CFTC Regulation 4.12 Pools, CFTC Regulation 4.13(a) (1) Pools, CFTC Regulation 4.13(a)(2) Pools, or CFTC Advisory 18-96 Pools. If an SEC-Registered Manager is also a CPO and/or a CTA, it must consider the requirements applicable to CPOs and/or CTAs discussed below, and vice versa. Similarly, if an Exempt Reporting Adviser is also a CPO and/or a CTA, it must consider the requirements applicable to CPOs and/or CTAs discussed below, and vice versa.
The calendar assumes the fiscal year is the calendar year; a fiscal year other than the calendar year will require the deadlines of some of the listed actions to be adjusted. For deadlines that fall on non-business days or holidays, please check the relevant filing site or contact a member of the Winston team for guidance.1 Please note that some filing obligations have been extended or delayed. For more information on these filings and changes, please see Sections 2 and 4. Regulatory requirements without fixed deadlines are listed at the end of the calendar. A Glossary of defined terms is included in Section 3.
Footnote
1. Section 13 reports (including Forms 13F and 13H and Schedules 13G) must be filed through EDGAR, the SEC's electronic filing platform, which is unavailable for submissions on weekends and certain federal holidays. Filers should also note that access to EDGAR now requires enrollment in EDGAR Next, the SEC's updated account access and management system. Enrollment requires submission of a Form ID application with a notarized signature. Because processing times may vary, firms are encouraged to complete enrollment well ahead of any applicable filing deadlines.
Form ADV and Form PF filings are made through FINRA's electronic filing system, which accepts filings made on weekends. Pursuant to Rule 0-4 under the Investment Advisers Act of 1940, as amended ("Advisers Act") filings are required on a weekend or holiday unless the Investment Adviser Registration Depository ("IARD") system is not available.
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