SEC Files Actions Against Six Firms for Misstatements in Form ADV Filings
SEC³ Compliance Alert
November 21, 2025
The SEC has brought enforcement actions against six entities that claimed to operate as investment advisers: Bluesky Eagle Capital Management Ltd., Supreme Power Capital Management Ltd., AI Financial Education Foundation Ltd., AI Investment Education Foundation Ltd., Invesco Alpha Inc., and Adamant Stone Limited. The matters were filed in federal courts in New York and Colorado and involve allegations that the firms submitted inaccurate, misleading, or unsubstantiated information in their Form ADV filings during 2023 and 2024.
According to the SEC’s complaints, each of the firms reported details about their operations, office locations, clients, and assets under management that did not match verifiable facts. Several entities listed office addresses in New York or Denver, yet the businesses currently occupying those locations stated that they had no connection to the advisers or their personnel. Some firms claimed to advise private funds and indicated that another registered adviser filed disclosures for those funds, but no such filings existed. Two of the firms also described themselves as publicly traded companies, though SEC records contained no evidence supporting that status.
When the SEC sought documentation to confirm assets under management, client relationships, and other statements made in Form ADV, none of the firms supplied the required records. As a result, each has been charged with violations of Sections 204(a) and 207 of the Investment Advisers Act of 1940, and the Commission is seeking injunctions and monetary penalties. The investigations remain ongoing.
Why This Matters
These cases highlight the SEC’s increased focus on the reliability of the information advisers submit in regulatory filings. Form ADV is the principal disclosure document used to assess an adviser’s business activities, conflicts, ownership structure, private-fund involvement, and operational footprint. When firms provide information that is inaccurate, incomplete, or cannot be substantiated during an examination, the SEC considers it a serious breach of trust and a direct violation of the Advisers Act.
The recent actions also show that the SEC does not limit its scrutiny to large or well-known firms. Advisers of any size, including newly registered entities or those with limited U.S. business activity, may face enforcement risk if their filings are inconsistent with reality or unsupported by records. At a time when the SEC is devoting additional attention to registration accuracy and cross-filing consistency, even small errors or assumptions can lead to regulatory challenges.
How SEC³ Compliance Can Help
SEC³ Compliance assists advisers at every stage of Form ADV preparation, review, and maintenance. Our work includes:
• Reviewing disclosures to ensure they accurately reflect business operations, ownership, office locations, advisory services, and assets under management.
• Verifying that private-fund reporting is complete and matches what is filed by related advisers.
• Ensuring that all claims in Form ADV are backed by appropriate books and records that can be provided to regulators promptly.
• Helping advisers evaluate whether their narrative disclosures align with actual operational practices.
• Conducting periodic reviews to identify inconsistencies between public filings, marketing materials, websites, and internal documentation.
• Preparing firms for SEC examinations and assisting in responding to document requests.
By building a clear, well-documented foundation for Form ADV and related disclosures, advisers can significantly reduce regulatory risk, improve transparency, and avoid the types of issues that led to the enforcement actions announced this month.
To review your Form ADV or discuss strengthening your compliance infrastructure, contact SEC³ Compliance.
Wishing you and your loved ones a wonderful Thanksgiving. Thank you for your continued partnership and support throughout the year.
Need assistance with your compliance program? SEC’s team of experienced compliance professionals can help. For more information, please email us at info@sec3compliance.com, call (212) 706-4029 x 214, or visit our website at www.sec3compliance.com.
SEC3 provides links to other publicly available legal and compliance websites for your convenience. These links have been selected because we believe they provide valuable information and guidance. The information in this e-newsletter is for general guidance only. It does not constitute the provision of legal advice, tax advice, accounting services, or professional consulting of any kind
Photo by Tamás Szabó on Unsplash
For over two decades, we have been providing compliance consulting services and servicing as outsourced Chief Compliance Officers. Our professionals have served as SEC regulators and in senior leadership, guiding the industry’s principal compliance association. Our consultants also have hands-on industry experience as chief compliance officers, experienced securities attorneys and senior management of investment advisers, broker-dealers and fund administrators.
What can SEC3 do for you?
SEC3 offers an extensive suite of customizable compliance services for investment advisers, private fund advisers, CPOs, CTAs, investment companies, institutional investors and broker-dealers which can complement your internal compliance program on a one-time or recurring basis depending on your needs.
Call us today at (212) 706-4029 x 229, or shoot us an email at info@SEC3compliance.com so we can set up a time for one of our consultants to discuss your needs and how we can help.