News & Events

Partner Meaghan Kelly was quoted extensively in a Regulatory Compliance Watch article titled, “Little Bark, Lots of Bite in SEC’s Priorities,” which detailed the SEC’s recently released 2025 Examination Priorities. Meaghan explained that “annual compliance reviews are increasingly an exam focus” and that “if they weren’t documented as part of the ordinary course of business,” summaries are typically requested in exams to demonstrate that the review was in fact done. She further addressed the marketing rule, noting that it “has been squarely in focus of exams for the past two years and will continue to be in focus,” and that “Managers should pay special attention to incorporating the impact of sub lines in the presentation of performance in marketing materials per the FAQ from earlier this year.” She also explained that “the rules don’t require the contemporaneous documentation of substantiation, but you do have to show it upon demand.” Meaghan also summarized that “The references in the exam priorities often have embedded meanings and history, and the priorities are really tying all those things together.”

To read the full article, please click here.