April 2026 Compliance News: Post-Filing Priorities for RIAs

After the annual Form ADV amendment season, April is the right time for RIAs to turn filings into action. Compliance news for April 2026 centers on post-filing cleanup, annual review planning, fee testing, and making sure disclosures align with day-to-day advisory practices.

The Filing Is Not the Finish Line

Once Form ADV is updated, firms should confirm that client brochures, website descriptions, pitch materials, agreements, privacy notices, and internal procedures tell the same story. Inconsistent language can create examination risk even when each document was prepared in good faith. Compliance teams should compare key statements about services, fees, conflicts, disciplinary history, custody, referral arrangements, and technology use.

Advisers should also review whether brochure delivery records are complete. If a material change occurred, the firm should document who received the updated brochure or summary of material changes, when delivery occurred, and how the firm handled clients with bounced emails or portal access issues.

Fee Billing Testing Should Happen Early

Fee billing remains a recurring exam focus. April is a good time to test whether billing rates, breakpoints, householding, credits, proration, advance or arrears billing, and terminated accounts were handled correctly. The test should compare client agreements, billing system settings, invoices, custodial deductions, and any manual adjustments.

When errors are identified, firms should document the root cause, client impact, reimbursement decisions, disclosure considerations, and control enhancements. Regulators generally expect more than correction. They expect evidence that the firm understood why the error happened and reduced the chance of recurrence.

Annual Review Planning Starts Now

Many RIAs wait until year-end to begin annual review work. A better approach is to build the annual review throughout the year. Compliance teams should map testing to the firm's risk areas, business changes, prior findings, exam priorities, and new technology. By April, the firm should know which areas will be tested quarterly, semiannually, or annually.

The annual review should also reflect changes in the business. New services, new client types, new marketing channels, mergers, personnel changes, outsourcing, model portfolios, or AI tools can change the compliance risk profile. The review process should capture those changes while there is still time to adjust policies and training.

Key Takeaways for RIAs

• Reconcile Form ADV with client-facing and internal materials after filing.
• Document brochure delivery and follow up on failed delivery attempts.
• Test fee billing early enough to remediate before issues compound.
• Build the annual review throughout the year instead of waiting until year-end.
• Use management reporting to keep remediation visible and accountable.