Compliance & Ethics

SEC Chairman Paul Atkins announced a proposal to fully rescind Rule 206(4)-5, the "pay-to-play" rule under the Investment Advisers Act of 1940, along with related recordkeeping requirements. Compliance teams at registered investment advisers should prepare for the potential elimination of political contribution monitoring and the two-year compensation ban, pending the formal rulemaking process and public comment period.

The FCA has added ExoticInvest Trading and Investment Firm to its Warning List for providing or promoting financial services in the UK without authorization. Consumers dealing with this firm have no access to the Financial Ombudsman Service or FSCS protection, increasing the risk of financial loss with no recourse. Compliance teams should treat this as a reminder to reinforce due diligence and third-party screening controls against unauthorized entities and clone firm scams.

The FCA's Smart Data Accelerator has published findings from a June 2026 policy sprint examining how open finance could transform mortgage journeys, concluding that infrastructure, trust, and accountability—not just data access—are the critical barriers to adoption. While this report sets no binding requirements, it signals likely future FCA policy direction on data standards, mandatory participation, and accountability frameworks that mortgage lenders and open finance participants should begin monitoring closely.

The FCA's Smart Data Accelerator has published findings from a June 2026 policy sprint examining how open finance could transform mortgage journeys, concluding that infrastructure, trust, and accountability—not just data access—are the critical barriers to adoption. While this report sets no binding requirements, it signals likely future FCA policy direction on data standards, mandatory participation, and accountability frameworks that mortgage lenders and open finance participants should begin monitoring closely.

The SEC is proposing to rescind the "pay-to-play" rule which restricts investment advisers from providing services to government clients following political contributions. This move addresses operational complexities and unintended consequences, such as the prohibition of state-level donations and strict liability for minor "foot faults."

The SEC

The Financial Conduct Authority (FCA) has issued a warning regarding "Swift TradeX," an unauthorized entity offering financial services in the UK. For compliance teams, this highlights the ongoing threat of fraudulent firms and underscores the necessity of verifying that all partners and service providers possess valid regulatory approvals.