2026 Q2 Training Requirements & Best Practices for Investment Advisers and Broker-Dealers

Annual compliance training remains one of the most visible and frequently evaluated components of a firm’s compliance program. For investment advisers and broker-dealers, training is not simply a procedural requirement; it is a key mechanism through which policies, regulatory expectations, and firm culture are translated into day-to-day behavior.

As firms move into the second quarter of 2026, many are in the process of conducting or refreshing annual compliance training programs. Regulators continue to view training as an indicator of whether a compliance program is reasonably designed and effectively implemented, particularly where training aligns with the firm’s actual risk profile and evolving regulatory environment.

Regulatory Expectations: Training as Part of a Reasonably Designed Program

Both the SEC and FINRA consistently emphasize training as a core component of supervisory and compliance obligations . While rules do not prescribe a single format or cadence for investment adviser training, expectations arise from broader requirements under Rule 206(4)-7 for advisers and supervisory obligations applicable to broker-dealers.

Examiners commonly assess:

• Whether training content reflects current regulatory risks and firm activities
• Whether employees understand policies applicable to their roles
• Whether attendance and completion are documented
• Whether training is updated in response to regulatory developments or internal findings

Training that is static or overly generic often raises questions about whether compliance expectations are meaningfully communicated across the organization.

Aligning Training with Real Risk Areas

Effective compliance training begins with risk identification. Rather than treating training as a standardized annual exercise, firms increasingly tailor content to address areas where risk is most likely to arise within their business.

Common Q2 training topics for investment advisers and broker-dealers firms include: Conflicts of interest and disclosure obligations

• Electronic communications and off-channel communications risks
• Cybersecurity awareness and data protection responsibilities
• Marketing and communications standards
• Personal trading and outside business activities
• AML and suspicious activity awareness (where applicable)

Training that reflects real-world scenarios tends to be more effective than policy summaries alone. Employees are more likely to recognize risks when training connects regulatory requirements to practical situations they encounter in their roles.

Moving Beyond “Check-the-Box” Training

One of the most common shortcomings in annual training programs is treating completion as the primary objective. While documentation remains important, regulators increasingly focus on whether training changes behavior and reinforces supervisory expectations.

Practical approaches that improve effectiveness include:

• Scenario-based discussions rather than policy recitation
• Role-specific training modules for different business functions
• Incorporating lessons learned from internal reviews or industry enforcement actions
• Providing opportunities for questions and discussion

Training should reinforce that compliance is an ongoing responsibility rather than an annual event.

Documentation and Demonstrating Effectiveness

From an examination standpoint, firms should be prepared to demonstrate not only that training occurred, but how it supports the broader compliance program. This may include:

• Training materials and agendas
• Attendance records and attestations
• Evidence of updates made to address regulatory changes
• Follow-up communications or supplemental training where needed

Documentation helps establish that training is part of a continuous compliance framework rather than a standalone requirement.

Keeping Training Relevant and Credible

A recurring challenge for many firms is maintaining engagement as training programs repeat annually. Over time, familiar material can lose impact, particularly where employees perceive training as routine rather than meaningful.

Refreshing content periodically, whether through updated examples, current regulatory themes, or external perspectives, can help maintain engagement and reinforce the seriousness of compliance expectations. In some cases, leveraging third-party professionals to assist with training development or delivery can introduce practical insights drawn from broader industry experience, helping reinforce key messages and providing an independent perspective that resonates with employees.

Ultimately, effective compliance training supports more than regulatory requirements. It reinforces culture, strengthens supervisory frameworks, and helps ensure that policies translate into consistent behavior across the organization: outcomes that remain central to sustainable compliance programs for both investment advisers and broker-dealers.