The December edition of The Salus GRC Brief is here — bringing together year-end regulatory signals, evolving SEC priorities, and a closer look at how AI and technology are reshaping compliance and operational oversight across financial services. 

As 2025 comes to a close, the regulatory environment is anything but quiet. From the SEC’s stated focus on modernization and targeted oversight to the growing role of AI in compliance programs, recent developments underscore a clear shift in how firms are expected to operate, document, and scale responsibly. 

This month’s Salus GRC Brief explores what these signals mean heading into 2026. Our team breaks down key SEC updates, emerging examination priorities, and practical considerations around AI adoption, cybersecurity, and valuation governance — alongside a message from our CEO as we look ahead to the year to come. 


SEC Signals Deregulation, Modernization, and AI Priorities 
Recent remarks from the SEC’s Division of Investment Management point to a measured shift toward deregulation, modernized rules, expanded access to alternatives, and thoughtful oversight of AI. Here’s what firms should be paying attention to as these priorities take shape. 

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SEC Delays Form SHO Reporting Until 2028 
The SEC has pushed the compliance date for Rule 13F-2 and Form SHO reporting to January 2028. We break down what the delay means, why it was widely expected, and how it fits into the Commission’s broader regulatory posture. 

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The Next Evolution in AI: Agents 
Firms are moving beyond AI experimentation and into scaled, enterprise-wide use cases. This article explores the rise of agentic AI, what it means for operations and compliance, and why delaying adoption may carry long-term costs. 

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SEC Division of Examinations Announces 2026 Priorities 
The SEC’s Division of Examinations has released its 2026 priorities, highlighting focus areas across advisers, funds, broker-dealers, cybersecurity, and emerging technologies. We summarize what’s new and what firms should expect heading into the next exam cycle. 

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Key Takeaways from the Salus GRC Webinar: Private Fund Valuation in the Hot Seat 
Private fund valuation remains under intense regulatory, investor, and audit scrutiny. Highlights from Salus GRC’s recent webinar examine governance expectations, documentation pitfalls, and best practices shaping today’s valuation landscape. 

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Salus GRC Updates 

Year-End Reflections & What’s Ahead 
As we close out 2025, we’re grateful for the trust our clients and partners place in us. In the year ahead, Salus GRC remains focused on helping firms navigate regulatory change with clarity, practical solutions, and technology-enabled oversight. 


Key Regulatory Deadlines 

  • December 1, 2025 – Q3 2025 CPO-PQR Filing Due (NFA/CFTC) 
  • December 8, 2025 – CRD/IARD Preliminary Renewal Payment Due 
  • December 26, 2025 – CRD/IARD System Shutdown 
  • December 26, 2025 – IAR Continuing Education Completion Deadline 
  • December 30, 2025 – Distribute Pool Participant Statements (NFA/CFTC) 

A Note from Bill Mulligan, CEO 

As we approach the end of 2025, I want to pause and express my sincere gratitude to our clients, partners, and the entire Salus GRC team for making this a year of meaningful progress and innovation. In an environment where regulatory expectations remain constant, your trust in our guidance — and our shared commitment to doing things the right way — continues to be the foundation of our growth. We are proud to stand beside organizations that take their responsibilities seriously, and equally proud of the work our team does every day to anticipate challenges and deliver thoughtful, practical solutions. 

I look ahead to 2026 with great enthusiasm. Against the backdrop of the SEC’s focus on measured deregulation, modernization, expanded access to alternative investments, and the promotion of artificial intelligence, our priorities remain clear. We are deeply focused on AI and technology, cybersecurity, continued innovation alongside our partners, and maintaining close attention to the evolving regulatory landscape. 

As the holiday season arrives, I hope you find time to rest, recharge, and celebrate with the people who matter most. Thank you for being part of our journey and for allowing us to be part of yours. We look forward to supporting you in the year ahead. 

Warm wishes for the holiday season, 

Bill Mulligan 
Chief Executive Officer 
Salus GRC