February 2026 Compliance News: RIA Exam Readiness and Disclosure Updates

February brought a practical compliance message for RIAs: regulators expect firms to connect written policies with actual supervision, testing, client communications, and vendor oversight. The latest compliance news points to a more evidence-based exam environment in 2026.

Exam Requests Are Becoming More Operational

Recent exam activity shows that regulators are asking for more than policy manuals. Firms should expect requests for testing calendars, exception reports, supervisory reviews, cybersecurity training evidence, advertising approvals, fee billing samples, and documentation of how compliance findings were remediated. This trend matters because many advisers have strong procedures but inconsistent proof that the procedures operate effectively.

Compliance teams should maintain a central evidence file that supports the annual review, exam readiness, and management reporting. The file should include dated approvals, meeting notes, issue logs, testing results, and follow-up items. If a control failed, the firm should document what happened, who reviewed it, and what changed afterward.

Disclosure Updates Remain a Priority

Form ADV and client brochure accuracy continues to be a central compliance theme. RIAs should review whether disclosures still match actual services, fee schedules, conflicts, referral arrangements, digital advice tools, outsourcing, and custody practices. Firms that changed technology providers, added AI-enabled tools, expanded model portfolio use, or revised fee structures should not wait until the annual amendment to identify disclosure gaps.

The strongest approach is to maintain a disclosure change log throughout the year. Business updates should be routed to compliance before marketing materials, client communications, or operational changes go live. That process helps prevent stale brochures, inconsistent website language, and unsupported marketing claims.

Marketing and Testimonials Need Better Substantiation

Marketing Rule compliance remains active in 2026. Advisers using testimonials, endorsements, social media, awards, or performance advertising should keep backup files showing approvals, required disclosures, compensation arrangements, and the basis for factual statements. Claims such as personalized service, proprietary process, lower risk, or superior technology should be reviewed for support before publication.

Firms should also confirm that archived posts, older pitch decks, and third-party profiles have not drifted away from current disclosure standards. Compliance failures often come from legacy content that was never retired, not from the newest campaign.

Key Takeaways for RIAs

• Build an exam evidence file that proves controls worked during the year.
• Update Form ADV and brochure language when business practices change.
• Keep substantiation files for marketing claims, testimonials, and awards.
• Track remediation so compliance issues do not repeat in the next review cycle.
• Make vendor, AI, and cybersecurity oversight part of routine governance reporting.