Annual compliance reviews under Rule 206(4)-7: the SEC Risk Alert of September 2026
The SEC’s September 2026 Risk Alert sets out issues examiners observed regarding adviser annual compliance reviews, including how advisers documented them.
Topic
The SEC’s September 2026 Risk Alert sets out issues examiners observed regarding adviser annual compliance reviews, including how advisers documented them.
The European Union prohibits several kinds of environmental claims outright from 27 September 2026. The United States, United Kingdom, Australia, New Zealand and Canada each use a different instrument, and in all six the evidence supporting a green claim is expected to exist when the claim is made.
Four marketing claims, each compliant in the market it was written for, tested across lending, insurance, healthcare and real estate in six jurisdictions. No approval applied beyond its own market, and in healthcare, the format itself was lawful in some countries and prohibited in others.
The EU has no single marketing regulator, and its rules take effect by date, not by instrument. A walk through the 2026 calendar, the AI Act's Article 50, the Empowering Consumers Directive, the Digital Fairness Act and the pending Green Claims Directive, plus the sectoral rules that carry no date.
The fourth Marketing Rule Risk Alert covers whether disclosure is present and prominent, and whether the firm can show why it believed the content complied.
When an advertiser claims a level of proof it cannot support, the claim itself is the violation, whatever the disclosures say. What the FTC substantiation standard requires before you publish, and why pointing to a study is not the same as holding the evidence.
Hidden ads and undisclosed reviews now breach four regulators' rules: ASA, CMA, FCA and FTC. What health marketers must disclose before they publish.
California's AI Transparency Act (SB 942) is operative from 2 August 2026. It settles AI-content provenance, not whether that content is compliant.
FINRA proposes to replace mandatory pre-use approval under Rule 2210 with firm-run, risk-based review of retail communications. How to prepare.
In a single day the ASA upheld findings in three sectors. Each firm had assumed its audience, channel, or format sat outside the rules.
FINRA named it a priority, but six regulators across five jurisdictions had already regulated it. Same conclusion, different frameworks.
FINRA's 2026 report gives generative AI a standalone section for the first time — governance, testing, and oversight expectations included.