UpFront » September 2026

The SEC has raised concerns that the use of AI systems at firms is outrunning its compliance oversight. The upcoming exam priorities agenda of the SEC will likely include reviewing firms’ AI governance and whether it is sufficient to keep guardrails on the use of AI for its intended purpose. Representatives from the SEC’s Division of Examinations have stated that it intends to review the controls and processes a firm has implemented around AI and…

The SEC will seek rule changes that will allow retail investors greater access to private markets. On the table are new ways for individuals to qualify as an accredited investor and giving investment advisers the ability to charge performance fees in retail funds by permitting new structures of regulated funds, multiple share classes and more frequent asset repurchases. FrontLine’s Founder and President Amy Lynch comments that allowing performance fees to be charged in retail funds…

A recent SEC Risk Alert focuses on how well investment advisers have complied with the Annual Compliance Review requirement of Rule 206(4)-7. Examination results show that many firms have received a failing grade when it comes to adequately completing their annual review according to the rule. Amy Lynch, FrontLine Compliance’s Founder and President, comments in the lead quotes that firms often fail to comply on a number of issues, with the timing of a firm’s…

The SEC has issued an anticipated proposal to revoke Rule 14a-8 governing public companies’ federal requirements on when to include shareholder proposals and their use in proxy materials. In its statement, the SEC is directing companies and their shareholders to rely on what is permitted by their individual state legislation. The SEC also proposed several other proxy-related rule amendments, including removing the requirement for companies to deliver an annual report to shareholders and eliminating the…