Embedded Files
A market digest for the next generation of RIAs, wealth managers & broker-dealers
· VOL. 1, ISSUE 01 · JULY 2026 ·
BREAKAWAY BRIEF
· LEAD STORY ·
Breaking Away is the Easy Part
More advisers than ever are leaving large firms to launch their own shops. But breaking away is the easy part. Standing up a registered investment adviser means building a compliance program, a legal structure, and an operating backbone from scratch, long before the first client is onboarded.
That build-out is where young firms stall or soar: in 2025 roughly 1,340 new advisers registered with the SEC while some 880 advisers filed to fully withdraw, according to the Investment Adviser Association and COMPLY’s 2026 Investment Adviser Industry Snapshot (June 2026). Learn more →
The firms that reach scale get their compliance, policies, and operations right from the start. Trilogic Partners is designed for exactly that: helping clients launch lean and stay examination-ready so that a firm can scale with confidence.
· VOL. 1, ISSUE 01 · JULY 2026 ·
· FIELD GUIDE · BUILDING YOUR PRACTICE ·
The Compliance Playbook
Building a Strong Foundation from the Start
Building a Strong Foundation from the Start
Standing up your own firm is only the start; the compliance and operating foundation you build next is what separates the firms that scale from those that never gain traction. This playbook highlights five practical moves for launching lean and staying examination-ready.
Set the Tone at the Top
Compliance starts with leadership. When leaders model ethics, back the compliance function and reward people who raise concerns, a genuine culture of compliance takes root. This is something examiners can sense and clients can immediately feel. Learn More →
Expect an Early Exam
The SEC has examined newly registered advisers as a priority since 2013 (SEC Division of Examinations, Newly-Registered Advisers Risk Alert, March 2023), and a first exam often lands within 12 to 18 months of registration. Build your program to be ready before they call. Learn more →
Tailor Your Program
Off-the-shelf manuals are the deficiency examiners cite most. Tailor policies to your real risks (portfolio management, fee billing, custody) and run the required annual review. Know your operations and your team so that the procedures address the greatest risk. Learn more →
Automate with AI
The hours spent on compliance are significant, with over 1,000 data points needed for the ADV alone (Investment Adviser Association & COMPLY, 2026 Investment Adviser Industry Snapshot, June 2026). AI tools help buy that time back. Make sure AI works for you, with proper documentation that is easily tested and tools that improve your efficiency. Learn more →
Mind the SEC Priorities
The SEC’s FY2026 exam priorities (SEC Division of Examinations, 2026 Examination Priorities) spotlight fiduciary duty, marketing-rule compliance, AI and GenAI use, cybersecurity and anti-money-laundering controls. Build strong controls from day one; regulators expect testable policies, not intentions. Learn more →
· VOL. 1, ISSUE 01 · JULY 2026 ·
· REGULATORY WATCH · SEC 2026 AGENDA ·
The SEC Resets the Rulebook
The July 7 SEC Release — A Deregulatory Turn
The July 7 SEC Release — A Deregulatory Turn
The SEC rolled out its 2026 Unified Agenda on July 7, 2026, and Chairman Paul Atkins framed all 38 rulemakings (36 proposed, 2 pre-rule) as a lighter-touch reset. Notably, the agency labeled every one of its Division of Investment Management items deregulatory — the strongest sign yet of an easier stance for advisers and funds (SEC, 2026 Unified Agenda and Regulatory Flexibility Agenda, July 2026). Learn more →
Pay-to-play rule eased — Proposed amendments to Rule 206(4)-5 would shorten the two-year “time-out” that bars advisers from earning fees on government-entity assets after a covered political contribution. (Proposal stage, Fall 2026)
Recordkeeping brought current — The books-and-records rule would be rewritten for cloud storage and off-channel messaging, replacing paper-era retention mandates with a technology-neutral standard. (Proposal stage, Fall 2026)
Electronic delivery by default — A new framework would make e-delivery the standard way to send prospectuses, shareholder reports and disclosures, ending the paper-first default that dates to the 1990s. (Proposal stage, Fall 2026)
Custody rebuilt for digital assets — A modernized custody regime would add safe harbors for crypto and tokenized securities, giving advisers a clearer path to hold digital assets with qualified custodians. (Proposal stage, Fall 2026)
Private markets opened to retail — Proposals would widen retail and 401(k) access to private funds and private-market strategies long reserved for institutions and accredited investors. (Proposal stage, Fall 2026)
A push to revive public markets — Atkins’ capital-formation package, which extends shelf registration, semiannual reporting and emerging-growth-company relief and rescinds the 2024 climate-disclosure rule, was proposed in May 2026. (Proposed May 2026, in comment)
What this means for your firm — A lighter, modernized rulebook lowers the cost of registering and scaling, but these are proposals, not final rules. Track the 60-day comment windows on items that touch your model and plan for phased effective dates rather than an overnight reset.
What this means for your firm — A lighter, modernized rulebook lowers the cost of registering and scaling, but these are proposals, not final rules. Track the 60-day comment windows on items that touch your model and plan for phased effective dates rather than an overnight reset.
· VOL. 1, ISSUE 01 · JULY 2026 ·
· REGULATORY WATCH · 2026 EXAM PRIORITIES ·
Where Examiners Will Focus in 2026
Lighter rulemaking does not mean lighter exams.
Lighter rulemaking does not mean lighter exams.
The SEC’s 2026 Examination Priorities single out six areas where new and growing advisers should expect the closest look (SEC Division of Examinations, 2026 Examination Priorities). Learn more →
The SEC’s 2026 Examination Priorities single out six areas where new and growing advisers should expect the closest look (SEC Division of Examinations, 2026 Examination Priorities). Learn more →
· VOL. 1, ISSUE 01 · JULY 2026 ·
· RESOURCES · TRILOGIC PARTNERS ·
For a Deeper Dive Explore Our Resources
GUIDE · COMPLIANCE PLAYBOOK
GUIDE · COMPLIANCE PLAYBOOK
Emerging Manager Compliance Playbook
A step-by-step manual for newly registered advisers standing up a program from day one. It walks through drafting your compliance manual and code of ethics, appointing a chief compliance officer, running the SEC-required annual review, and building the books-and-records system examiners now expect. Includes a first-year calendar and Form ADV filing checklist. Open the playbook →
GUIDE · CULTURE & GOVERNANCE
GUIDE · CULTURE & GOVERNANCE
Building Your Compliance Culture
Practical ways to embed a culture of compliance across a growing firm, from the tone leadership sets at the top to the daily habits that keep advisers on the right side of the rules. Covers conflicts-of-interest disclosure, personal-trading policies, marketing-rule review, and vendor oversight, with sample governance charters and a quarterly compliance-committee agenda you can adapt. Open the guide →
BRIEFING · REGULATORY OUTLOOK
BRIEFING · REGULATORY OUTLOOK
SEC 2026 Exam Priorities Decoded
A concise reading of the SEC Division of Examinations' 2026 priorities and what they mean for a small shop. We translate the agenda (fiduciary duty and Reg BI, off-channel communications, cybersecurity and data protection, AI-driven advice, and the marketing rule) into a short list of the questions examiners are most likely to ask and the documents you should have ready before they call. Open the briefing →
· VOL. 1, ISSUE 01 · JULY 2026 ·
· THE FOUNDERS · TRILOGIC PARTNERS ·
Meet the Founders
Amber D. Baker, Esq.
Amber D. Baker, Esq.
Chief Executive Officer
Chief Executive Officer
Amber is a dynamic, cross-functional executive with nearly 20 years of financial services experience. After Harvard Law School, she built her foundational knowledge at law firms WilmerHale and K&L Gates and then went in-house at Natixis and Citibank. Ultimately, she found her niche in helping start and lead young asset managers and RIAs, including when, as Deputy CEO, she helped her company successfully navigate twentyfold growth in three years.
Kristina Patyjewicz
Kristina Patyjewicz
Chief Compliance Officer
Chief Compliance Officer
Kristina is a compliance professional with 20 years of experience tackling regulatory challenges. Kristina optimized risk management and streamlined operations at Mirova US, PSG Equity, L.L.C., The Baupost Group, L.L.C., and Arrowstreet Capital, L.P. As a graduate of McGill University (BA) & the University of Albany (MPA) she brings strong academic and professional foundations to her role as Chief Compliance Officer.
· VOL. 1, ISSUE 01 · JULY 2026 ·
· SOURCES & CITATIONS ·
Research Further
PART 1 · BREAKING AWAY IS THE EASY PART
~1,340 new RIA registrations, ~880 full withdrawals (2025)
Investment Adviser Association & COMPLY, 2026 Investment Adviser Industry Snapshot (June 2026) · read article
PART 2 · THE COMPLIANCE PLAYBOOK
SEC exams newly-registered advisers (first exam 12 to 18 months)
SEC Div. of Examinations, Newly-Registered Advisers Risk Alert (Mar 2023) · read article
FY2026 exam priorities: fiduciary, marketing, AI, cyber, AML
SEC Div. of Examinations, 2026 Priorities · read article
The average SEC registered adviser provided over 1,000 pieces of information in Form ADV
Investment Adviser Association & COMPLY, 2026 Investment Adviser Industry Snapshot (June 2026) · read article
PART 3 · REGULATORY WATCH
SEC 2026 Unified Agenda (July 7, 2026)
SEC, Chair Atkins, 2026 Reg. Agenda (Jul 2026) · read article
K&L Gates, The SEC’s New Rulemaking Agenda: A Deregulatory Road Map for Advisers and Funds (July 8, 2026) · read article
Proskauer, SEC 2026 Agenda: Key Takeaways for Investment Advisers and Investment Companies (July 9, 2026) · read article
Marketing Rule enforcement focus
SEC, Marketing Rule Risk Alert (Dec 2025) · read article
PART 4 · EXAM PRIORITIES
Six 2026 exam focus areas for new advisers
SEC Div. of Examinations, 2026 Priorities · read article
K&L Gates, SEC Examination Priorities Show Continued Focus on Risks in Changed Enforcement Environment (December 1, 2025) · read article
Proskauer, 2026 SEC Examination Priorities for Investment Advisers – Same Tune, New Notes (November 24, 2025) · read article
Marketing Rule: testimonials, endorsements, performance ads
SEC, Marketing Rule Risk Alert (Dec 2025) · read article
PART 5 · RESOURCES
Emerging Manager Compliance Playbook
Trilogic Partners, Compliance Playbook (Guide) · read article
Building Your Compliance Culture
Trilogic Partners, Culture & Governance (Guide) · read article
SEC 2026 Exam Priorities Decoded
Trilogic Partners, Regulatory Outlook (Briefing) · read article
· VOL. 1, ISSUE 01 · JULY 2026 ·
· PRINT VERSION ·
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