The SEC’s Spring 2025 Unified Agenda is out. And it’s clear: registered investment advisers (RIAs) are poised to see impacts with key rulemakings on the horizon.
While many item specifics are still pending – or will be laid out in proposed rules – there’s already enough clarity to anticipate the most consequential changes and prepare accordingly.
Most Impactful Regulatory Areas & Likely Implications
1. Customer Identification Programs (CIP/KYC)
The SEC intends to finalize rules requiring RIAs and ERAs to implement customer identification procedures under Section 326 of the USA PATRIOT Act. Put simply, these will require firms to verify their clients’ identities when opening accounts.
Timeline: Final Action currently slated for April 2026.
Implications: RIAs must prepare to overhaul onboarding workflows, incorporate identity-verification tools or vendors, train staff, and handle enhanced documentation and recordkeeping.
What to do now: Conduct a gap analysis of current client intake processes, identify identity-verification service providers, and budget for compliance tooling and training.
2. Custody Rule Amendments (Including Crypto)
A modernization of custody rules – including explicit provisions for crypto assets – is on the horizon, with a Notice of Proposed Rulemaking (NPRM) planned for April 2026. With these updates, custody rules (which govern how advisers handle client money and securities) will specifically address crypto assets, which haven’t been clearly covered before.
Timeline: Notice of Proposed Rulemaking (NPRM) currently slated for April 2026.
Implications: RIAs with custody or access to client assets must re-evaluate custodial selection, vendor oversight, control protocols, and surprise exam readiness. Crypto advisers will face additional complexity: key management, segregation, insurance, and attestation requirements.
What to do now: Review and fortify vendor due diligence, custody agreements, and operational controls; begin researching crypto custody frameworks if applicable.
3. Financial Data Transparency Act – Joint Data Standards
The SEC will coordinate with other agencies to establish data standards and interoperability for regulatory reporting. With these shared standards, filings and reports become easier to compare, search, and use across agencies.
Timeline: Final Action currently slated for December 2025.
Implications: Firms submitting regulatory filings – including advisers with registered funds – will eventually need to align internal systems with new standardized taxonomies, identifiers, and reporting formats.
What to do now: Engage with your fund administrator, compliance vendor, or IT team to understand potential mapping or automation needs; prioritize building data pipelines and standard identifier usage (e.g., LEI, CUSIP).
4. Amendments to Form N-PORT
The SEC is considering recommending changes to Form N-PORT, which funds use to report details about their portfolios. The aim, per the SEC, is “to address identified disclosure burdens.”
Timeline: Notice of Proposed Rulemaking (NPRM) currently slated for April 2026.
Implications: Form N-PORT requirements may shift – potentially changing what needs to be reported, how often, or how detailed filings must be. Even if some burdens are reduced, firms may still need to adjust data collection, review processes, and reporting schedules.
What to do now: Begin assessing current data collection and reporting workflows; engage with your admin team or vendor to discuss how potential N-PORT updates may alter timelines and disclosure procedures.
5. Crypto Assets Rulemaking (Offer & Sale Frameworks)
The SEC is considering a proposal on how crypto assets can be offered and sold. The rules could include exemptions or safe harbors, aimed at giving firms more clarity on what’s permitted and reducing uncertainty in the market.
Timeline: Notice of Proposed Rulemaking (NPRM) currently slated for April 2026.
Implications: Advisers offering crypto-related investment products may need to re-evaluate product structures, disclosures, suitability assessments, and operational capabilities amid evolving regulation.
What to do now: Monitor the emerging framework, update crypto-related policies and disclosures, and be ready to modify or halt product offerings pending clarity.
Strategic Next Steps
- Audit Your Firm’s Exposure: Identify whether you custody assets, manage funds, or offer crypto – those are high-impact areas.
- Gap assessments: Perform early reviews of onboarding (CIP), custodial controls, data/reporting systems, and crypto policies.
- Vendor engagement: Initiate conversations with ID verification, reporting, custody, and fund administration providers to prep for pending changes.
- Policy updates: Pre-draft revisions to client agreements, ADV disclosures, and operations manuals.
- Resource planning: Budget for compliance technology, additional staff, or outsourced support.
- Stay informed: Track rulemaking timelines and review proposed rules upon publication to refine planning.
Wrap Up
The SEC’s 2025 agenda signals tangible changes for RIAs in the near term – from client onboarding and custody to fund reporting and crypto offerings. Firms that anticipate these shifts now will gain an operational edge, while less-prepared peers risk last-minute fire drills or disruptions when rules land.
At Comply, we help firms turn those pressures into a plan. Our platform and consulting services are built by compliance leaders who understand both the letter of the rules and the realities of running a program. From risk assessments and policy oversight to trade monitoring and annual reviews, Comply equips firms with the structure, insight, and confidence to stay exam-ready without the scramble.
Ready to build a stronger compliance program? Let’s talk.