SEC Unveils Spring 2025 Agenda, Targets Adviser Custody and ID Rules

On September 9, 2025, the U.S. Securities and Exchange Commission released its Spring 2025 Unified Agenda, highlighting forthcoming rulemakings for investment advisers on custody, customer identification, and affiliated transactions.

The agenda underscores the SEC’s push to modernize Investment Advisers Act and Investment Company Act regulations, aiming to bolster client protections and adapt to emerging asset classes.

Key Rulemakings for Investment Advisers

Custody Rules Overhaul
- Proposals under consideration to strengthen and clarify custody requirements for client and fund assets, including treatment of crypto holdings.
Customer Identification Programs (CIP)
- Joint final rule with FinCEN mandating registered and exempt reporting advisers to verify client identities and maintain robust anti-money laundering controls.
Rule 17a-7 Amendments
- Potential expansion of Section 17(a) exemption to facilitate affiliated transactions between funds and certain related parties.
Form N-PORT Revisions
- Proposed amendments aimed at reducing disclosure burdens and streamlining reporting for registered funds.

Nut Graf

These measures reflect the SEC’s dual focus on enhancing investor safeguards and reducing outdated disclosure requirements, while ensuring the regulatory framework keeps pace with digital assets and new market structures.

Regulatory Timeline and Next Steps

April 1, 2026 is the target date for next actions on all highlighted proposals.
Chairman Gary Gensler has emphasized tailored, risk-based regulation and signaled further deregulatory reviews of legacy proposals.

The Spring Agenda offers advisers a roadmap of forthcoming compliance milestones. Firms should begin reviewing their custody and anti-money laundering programs now to prepare for formal rule proposals and public comment periods early next year.