The SpaceX IPO in June 2026 was the largest in history. It was also, for hundreds of retail investors, the moment they discovered that the pre-IPO shares they thought they owned were not what they had been told -- and that the fees they had been charged were nothing like what had been disclosed. The SEC filed its complaint against Andrew Spaventa and his network of entities on August 14, 2026. I read it carefully. What follows is not a legal analysis -- I'm not acting as anyo

Your first SEC examination is not just a regulatory event. It is the first time a federal regulator will look closely at how your firm operates, how you treat clients, and whether the compliance program you built on paper actually functions in practice. The outcome matters -- not just for the examination itself, but for how your firm is perceived in every interaction with the SEC that follows. A CCO of a RIA meeting with an SEC examiner. Most of the mistakes I see smaller RIA

"Recidivism" is a word I learned early in my stint as an SEC examiner. It was important back then and it is just as important today. When an examiner sees that a past deficiency has not been corrected or taken seriously, alarm bells go off. It signals that the firm does not take SEC rules seriously -- and in my experience, that signal is almost never wrong. Firms that ignore prior findings rarely have just one problem. They tend to have several, and the examination that was s

Private equity firms get examined differently than other investment advisers. The SEC knows that the conflicts in this business are structural -- fees, carry, expense allocations, co-investments, GP relationships -- and examiners arrive expecting to find them. What separates firms that walk away clean from firms that end up with deficiency letters is rarely whether conflicts exist. It's whether the firm identified them, disclosed them properly, and built controls around them

The most dangerous moment in a hedge fund's regulatory life is not the first SEC examination. It's the period between registration and that first examination -- usually two to four years -- when nothing has gone wrong yet and compliance feels like paperwork rather than protection. I examined funds at the SEC that were technically registered but operationally unprepared. The gaps were almost always the same, and almost always avoidable. If you are starting up a hedge fund righ

In the ever-evolving landscape of financial regulation, firms must be prepared for scrutiny from the Securities and Exchange Commission. Mock SEC examinations serve as a vital tool for firms to assess their compliance readiness and identify potential weaknesses before the real thing occurs. This blog post will guide you through the importance of mock examinations, how to prepare effectively, and the benefits they offer to your firm. A compliance checklist laid out for review

Growth creates risk. As AUM increases, so do client expectations, product complexity, employee headcount, and SEC scrutiny. Many RIAs outgrow their compliance programs not because the rules change, but because the firm does. What worked at $100 million AUM often breaks at $1 billion. A scalable compliance program is not just larger—it is structured differently. It is repeatable, testable, and operationally embedded. Below is a practical framework for building one that keeps p

The SEC’s amendments to Regulation S-P materially raise expectations around how RIAs safeguard client information and respond to incidents. For smaller RIAs, the June 3 compliance date is imminent. The rule is not just about having policies—it is about demonstrating that those policies are operational, tested, and consistently followed. Below is a practical framework to help firms implement a program that is both workable for staff and defensible under SEC scrutiny. 1. Refram

Regulatory expectations for crypto firms have not emerged through a single rulemaking. Instead, the U.S. Securities and Exchange Commission has articulated its position through a combination of staff guidance, enforcement actions, and examination priorities. Across these developments, a consistent message has emerged: crypto firms operating in or accessing the U.S. market are expected to apply existing securities law frameworks with full rigor , not modified or informal inter

As the midterm election cycle accelerates, registered investment advisers should expect increased scrutiny around political contributions and interactions with public officials. The SEC’s Pay-to-Play Rule, Rule 206(4)-5, is clear in its intent: to prevent advisers from using political contributions to influence the award of advisory business from government entities. What is less clear in practice is how quickly ordinary activities—small contributions, informal conversations,