Industry Insights

Simplified MiFIR Transaction Reporting Still Needs Good Data Quality

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When the FCA published Consultation Paper 25/32 in November 2025, it signalled the most significant rethink of UK transaction reporting since MiFID II. The direction of travel has been broadly welcomed across the market, but what makes CP25/32 particularly noteworthy is that industry consensus alone will not deliver meaningful change. Whether these reforms reduce cost […]

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Building Controls That Stand Up to Regulatory Scrutiny

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As AI becomes woven into the fabric of investment research, operations, and client service, investment advisers face a fundamental shift: AI is no longer an experimental tool. It is an organizational capability that requires structure, oversight, and defensible controls. For a regulated firm, the decision to adopt AI is never just a technological one. It

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FCA Annual Work Programme Signals Sharper Supervisory Focus

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The FCA’s Annual Work Programme for 2026/27 provides one of the clearest statements yet on how the regulator intends to supervise firms as it enters the second year of its five-year strategy. While many of the themes will feel familiar, the programme connects strategic ambition with supervisory execution. This is not simply a forward-looking policy

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Proposed Clarifications to the Scope of Securities Exchange Act of 1934 Rule 15c2-11

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The SEC introduced Rule 15c2-11 to prevent certain manipulative and fraudulent trading schemes that had arisen in connection with the distribution and trading of unregistered securities issued by shell corporations or other companies with thin markets. The SEC has amended the rule several times over the years to address transparency issues, among other things. Rule

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How Valuation Decisions Ripple Through Private Credit Structures

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Valuation sits at the center of how private funds, investment companies, and BDCs operate. It lives in the net asset value (NAV), in the number investors transact on, the base for management and incentive fees, and the reference point for redemptions and marketed performance. Because of that position, valuation is an imperative operating assumption, and

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FINRA Updates CAB Rules Effective March 2026

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Effective March 25, 2026, FINRA adopted amendments to the Capital Acquisition Broker (CAB) rules to help reduce regulatory burden for firms seeking to move to the CAB model. These changes may expand a firm’s activities and enhance their competitiveness with traditional investment banking firms. While FINRA members are still required to maintain and enforce Written

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What Outcomes-Based Supervision Means in Practice for Wholesale Markets Firms in 2026

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The FCA’s inaugural Wholesale Markets Regulatory Priorities report signals a more structured and more demanding phase of supervision for firms, including wholesale banks and brokers, corporate finance firms, and principal trading firms. While the regulator continues to champion proportionate regulation and UK market competitiveness, it is equally clear that firms unable to evidence robust controls,

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Why Surveillance Programs Succeed or Fail

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Calibration Is Key to a Program’s Success or Failure Across global markets, regulators have consistently enforced that a trade surveillance system is only as strong as its calibration. The FCA puts it plainly: “Market abuse surveillance across industry can take many forms. It is often challenging and complex. Appropriate tailoring of alert models, which we

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How ACA Helped a Growing Advisory Group Launch an Independent RIA

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Client Background A growing investment advisory group engaged ACA to support their strategic move to break away and separate their advisory business from their current corporate partner. This group’s goal was to establish a fully independent Registered Investment Adviser (RIA). While the group intended to maintain their existing broker-dealer relationship, they anticipated that the transition

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