Practical Compliance Tips to Finish 2025 Strong
By DeeAnn Dempsey, Director
The final weeks of the year are an ideal time for registered investment advisers to complete essential compliance and operations tasks, refresh key policies, and prepare for a confident start to 2026. With holiday activity at its peak, it is also a practical moment for leadership to reinforce ethical standards around gift giving and entertainment.
Holiday Season Code of Ethics Reminders
The holiday season often brings an increase in gifts, dinners, and event invitations from clients and service partners. Clear guidelines help teams navigate these engagements while protecting the firm and its people from avoidable conflicts.
1. Gift Giving & Receiving
Reconfirm firm limits for the value of gifts employees may give or accept.
Reinforce that gifts from service partners, such as brokers, custodians, or vendors, must be evaluated for conflicts of interest.
Share real world examples of gifts that must be declined and suggested language for respectful, compliant responses.
2. Entertainment & Invitations
Clarify the difference between reasonable business entertainment and a reportable gift under the adviser’s policies.
Remind teams to report holiday dinners, ticketed events, or other forms of invitation-based entertainment.
3. Reporting Expectations
Reconfirm where and how gifts, entertainment, personal securities accounts, political contributions, and outside business activities are logged.
Encourage staff to check internal compliance dashboards or reporting workflows for any incomplete or unsubmitted items.
2025 Year End Compliance Checklist for Investment Advisers
Code of Ethics & Personal Trading
Remind employees of key reporting deadlines, including:
Annual Code of Ethics Attestations
Quarterly Transaction and Annual Holdings Reports
Review personal securities transaction and holdings reports for completeness.
Confirm access persons disclosed all required accounts, including those opened during 2025.
Ensure all applicable logs (gifts, entertainment, political contributions, and outside activities) are current.
Compliance Program & Risk Oversight
Confirm all 2025 items on the Compliance Calendar are completed or documented with owners and follow-up dates if rolling into early 2026.
Where tasks must carry over, set clear follow-up dates and communicate those next steps to relevant owners.
Assemble documentation and begin the 2025 annual compliance review for firms operating on a calendar-year review period.
Review risk assessments for material business or operational changes that occurred during 2025.
Refresh the conflicts-of-interest inventory and validate that disclosures in the firm’s Part 2A brochures remain accurate.
Identify policies requiring updates to reflect current operations and 2025 regulatory expectations, documenting owners and implementation timelines for Q1 2026.
Books & Records
Confirm archiving systems captured required communications, including email, SMS/text messages, collaboration tools, websites, and social media.
Perform a focused retention audit on messaging platforms used during 2025.
Preserve advertising and marketing materials that were distributed or published in 2025.
Regulatory Filings & Registrations
Confirm registration renewals and state notice filings are accurate for both investment adviser representatives and the RIA.
If state registrations or notice filings must be withdrawn or updated, ensure updates are completed before December 26, 2025 at 6:00 PM ET to avoid 2026 renewal fees.
Review for developments that may require an interim ADV amendment before year end.
Map owners and completion timelines for:
The 2026 Annual Form ADV Updating Amendment
The 2026 Form ADV Brochure Delivery Deadline
Internal Operations & Training
Deliver a short year-end compliance refresher or training session.
Review open compliance issues for inclusion in Q1 2026 planning.
Update and publish the 2026 compliance calendar, assigning recurring tasks and owners.
Looking Ahead: Build the 2026 Compliance Calendar Now
A well-designed compliance calendar reduces operational surprises and strengthens readiness for regulatory examinations. Every calendar should be customized to the firm’s business model, but at a minimum should track core mandatory obligations, including:
2026 annual ADV amendment and brochure delivery timelines
Quarterly transaction and annual holdings reporting deadlines
13F or other applicable SEC filings, where required
PTE 2020-02 Annual Review for firms making ERISA rollover recommendations
Annual compliance review
Regulation S-P updates
Policy ownership and internal target dates for completion
As 2025 ends, finishing key compliance and operations work with structure and ownership allows firms to reduce risk and build momentum for 2026. A completed compliance program and accurate records create confidence today, and clarity for what comes next.
Close 2025 with intention. Start 2026 with confidence.