• Pay-to-play rule - Recission proposed — The SEC has proposed rescinding Rule 206(4)-5 in its entirety, eliminating the federal two-year “time-out” that currently bars advisers from providing compensated advisory services to a government client following certain political contributions. (Comments Due Nov. 9, 2026)

• Recordkeeping - Modernization still on the agenda — The SEC has contemplated broader modernization of the books-and-records framework for cloud storage and electronic/off-channel communications, but no corresponding 2026 proposal has been issued. The pay-to-play proposal separately would remove recordkeeping provisions tied to Rule 206(4)-5.   Existing requirements remain in effect.(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. (Comments closed Sept 21, 2026, Final Rule Pending)

• Digital assets — New crypto framework proposed  — Proposed Regulation Crypto Assets would establish tailored exemptions and a conditional safe harbor for certain crypto-asset investment contracts. (Comments due Oct. 20, 2026)  

• Custody for crypto —  New Framework proposed  — 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 retail  — Access proposed —  Sept. 30 proposals would modernize performance-based compensation, interval funds and multiple share classes for registered closed-end funds and BDCs. The SEC is separately seeking comment on professional credentials and a potential FINRA exam as additional pathways to accredited-investor status. (Proposal stage, Fall 2026)

• Form PF — Compliance deadline pushed to 2027— The SEC and CFTC extended the compliance date for the 2024 Form PF amendments to July 1, 2027, giving private-fund advisers additional implementation time.  (Compliance deadline pushed to 2027)

• Public Markets — Capital formation reforms proposed — The SEC’s May proposals; including allowing eligible companies to move from quarterly to semiannual reporting using new Form 10-S, expanding emerging-growth-company and filer-status accommodations, and modernizing shelf-registration and registered-offering rules; are aimed at reducing burdens on public companies and facilitating capital formation. For RIAs, the significance is primarily indirect: these changes could affect the public companies in which advisers invest and the broader public/private market landscape. (Proposals remain pending)

• Proxy rules  — Major changes proposed  — The SEC has proposed rescinding Rule 14a-8 and modernizing proxy-solicitation rules, including changes to shareholder proposals and broker search periods. (Comments due Nov. 20, 2026) 

• Trading hours —  Moving toward 23/5 — The SEC and U.S. exchanges are moving toward extended equity-market trading hours, with proposals for 23 hours a day, five days a week, not universal 24/7 trading. For RIAs, the potential impact could include changes to best execution, valuation, liquidity, order handling, trading oversight, and compliance coverage as extended hours become operational. No universal 24-hour requirement has been adopted. (The initiative remains under development)

• Transfer agents — Modernization proposed — The SEC has proposed updating transfer-agent rules to reflect electronic communications, blockchain technology, and current operating practices. (Comments due Nov. 3, 2026)

For RIAs, the SEC’s 2026 rulemaking points toward more flexibility, more digital operations, and broader access to private markets, but little changes today. Most of the initiatives remain proposals, so firms should continue following existing requirements while watching for final rules.

The potential impact is significant: pay-to-play restrictions could ease, electronic delivery could become the norm, crypto custody could become more workable, and private-market opportunities could expand. At the same time, changes to recordkeeping, trading hours, proxy rules, and Form PF could require updates to policies, systems, and controls as the rules evolve. It's always helpful to keep this in mind as you plan for 2027. 

Bottom line: Now is the time to monitor, assess, and prepare; not to assume the proposed changes are already in effect.