If you blinked in early May, you missed a lot. The first three weeks of the month produced more substantive guidance for alternative fund managers than most full quarters do, and almost none of it was the kind you can file away for later. 

A new enforcement director at the SEC laid out his priorities at the Managed Funds Association conference. AIFMD II officially took effect across the EU. The Financial Stability Board published a fresh report on private credit vulnerabilities. FinCEN and OFAC proposed AML rules for stablecoin issuers under the GENIUS Act. And the Form PF compliance deadline keeps creeping toward October, no matter how many times it gets pushed.

Let’s get into it. 

New SEC Enforcement Director Puts Private Funds in the Crosshairs

The SEC has a new top cop, and he wasted no time telling everyone where he’s pointing the flashlight. One week into the role, David Woodcock used his first public address to telegraph what the Division of Enforcement plans to pursue under Chairman Atkins. The tone was “quality over quantity,” but if you run a private fund, you get top billing.

What Woodcock Flagged for Fund Managers

His named priorities read like a checklist of everything that’s ever gone wrong in a private fund examination: valuation practices on illiquid assets, fee and expense disclosures, undisclosed conflicts of interest, liquidity and suitability concerns, and misappropriated client assets. Woodcock also confirmed that the Retail Fraud Working Group is back, and he made a pointed reference to monitoring “stresses in some portfolios” across the private credit sector. That last phrase is doing a lot of work, and we’ll come back to it shortly.

What This Means for Your Documentation

Fewer cases don’t mean lighter ones. The cases that do move forward will be deeper, more document-intensive, and laser-focused on what your records show line by line. Valuation memos, fee waterfall calculations, conflict-of-interest disclosures: they need to hold up as written today, not after an inquiry letter shows up at the front desk. If your valuation policies haven’t been refreshed since 2023, treat this as your nudge.

AIFMD II Goes Live for EU Cross-Border Marketing

Five years of drafting, debate, and delays finally collided with the calendar on April 16, the transposition deadline for AIFMD II. The EU is now operating under the revised framework, which amends both the 2011 AIFMD and the UCITS Directive. If you’re a U.S. or U.K. manager raising capital in Europe, this is the one to read twice.

The Big Changes for Non-EU Sponsors

For managers using national private placement regimes under Articles 36 and 42, the headline shifts are expanded Article 23 pre-investment disclosures covering delegation, liquidity tools, loan portfolios, and fees, plus expanded Annex IV supervisory reporting under Article 24. Open-ended AIFs must pick at least two liquidity management tools from the harmonized list and bake them into the fund’s constitutional documents. AIFMD II also rolls out the first EU-wide regime for loan-originating AIFs, which has been a long time coming if you’ve been in this market.

Why the Domicile List Matters

Don’t overlook this. AIFMD II includes an outright ban on NPPR marketing where either the fund or the manager is domiciled in a jurisdiction on the EU’s AML high-risk or tax non-cooperation lists. The British Virgin Islands recently landed on the AML list, which means BVI-domiciled funds lost EU NPPR access on April 16 with no transitional grace period. None. If your structure runs through a jurisdiction that ends up on either list, your European fundraising pipeline can close overnight. Worth a 20-minute conversation with whoever maintains your structure chart.

Private Credit Hits a Regulatory Reckoning

This is where Woodcock’s comment about private credit “stresses” stops being a one-off and starts looking like a coordinated message. Two heavyweight regulators put the asset class in the spotlight within weeks of each other, and the third sits in Washington. When the IMF, the FSB, and the SEC all reach for similar language about the same corner of the market, it’s usually time to pay attention.

What the IMF and FSB Flagged

The IMF’s April Global Financial Stability Report called out rising hedge fund leverage, $4.5 trillion in bank exposure to non-bank financial institutions, and converging headwinds across private credit. On May 6, the FSB followed with its own report on private credit vulnerabilities that flagged the absence of a harmonized definition for the asset class and the cross-border data shortfalls that come with it. The IMF noted that roughly 15% of the $2 trillion direct lending universe sits in semi-liquid vehicles where investors can redeem. However, most have gates that keep systemic risk contained for now.

Why LPs and Auditors Will Press Harder

Now layer in Director Woodcock’s May 13 reference to private credit “stresses” and the Tricolor and First Brands collapses that are still fresh in everyone’s memory. The picture for fund managers gets pretty clear pretty fast. LPs are going to press harder on valuation methodology, NAV financing, and continuation-vehicle treatment. Auditors will probe asset-based lending and receivables collateral with more skepticism than they did 18 months ago. That said, if your valuation files can withstand that kind of scrutiny, you’re going to have an easier time at your next annual meeting than the manager sitting across the table from the same LP.

Stablecoins and Crypto Reporting Take Shape

You’d be forgiven for thinking this section doesn’t apply to you. But even funds that don’t touch digital assets directly should keep half an eye on what’s happening here. The perimeter around crypto is hardening fast, and it’s dragging tax and AML scrutiny along with it.

The GENIUS Act AML Rules

On April 8, FinCEN and OFAC issued a joint proposed rule treating permitted payment stablecoin issuers as Bank Secrecy Act financial institutions. The proposal requires full AML programs, sanctions compliance programs, and SAR filings from those issuers, with comments due June 9. Earlier this year, the OCC issued parallel rulemaking for bank-affiliated issuers. If your fund accepts stablecoin subscriptions or settles in them, your counterparty’s compliance lift is about to get a lot heavier, and some of that lift will land on your operational team.

Form 1099-DA and Cross-Border Reporting

Meanwhile, the first Form 1099-DA filing season is live for digital asset sales. Any fund that holds digital assets, accepts crypto subscriptions, or settles in stablecoins needs basis-tracking that reconciles to broker statements. Internationally, the OECD’s CARF framework and the EU’s DAC8 directive both took effect on January 1, with the first cross-border data exchanges expected in 2027. For managers with European or South American LPs, the documentation lift has already started, whether your tax team has internalized it yet or not.

The 2026 Compliance Calendar Tightens

Let’s end where most fund CFOs spend the bulk of their time: the calendar. A handful of dates are sitting there that fund principals should plan around now. Some have been delayed before. Most won’t be delayed again.

Form PF, Form 13F, and the October Deadline

The SEC and CFTC extended the Form PF amendment compliance date to October 1, 2026, the third such extension and probably the last. Before that one lands, August 14 brings the next quarterly 13F filing, and August 29 is the next large hedge fund adviser quarterly Form PF. When the amendments take effect on October 1, expect expanded master-feeder, exposure, counterparty, and liquidity reporting. Dual-registered CPOs and CTAs are squarely in scope, so if that’s you, the prep work starts now.

The AML Reprieve, and What Not to Do With It

One piece of regulatory breathing room: FinCEN’s investment adviser AML rule has been pushed to January 1, 2028. The substance of the rule is still intact, however, and FinCEN has signaled it may revise the scope before the new effective date. Translation: keep building the program. Don’t bet the firm on a rollback that hasn’t been announced.

When Everyone’s Asking the Same Questions

Step back from all five stories and the message writes itself. Whether it’s coming out of Washington, Brussels, or Basel, regulators are fixated on the same short list: how you value what you hold, how you handle liquidity, what you tell investors, where you market, and whether your paper trail backs any of it up. None of that is new. What’s new is that everyone is asking at once.

Which is exactly the moment to have the right people in your corner. Here’s what we at Michael Coglianese CPA, P.C. can do for firms like yours:

• Audits & Assurance: Explicitly built for alternative investment firms, not retrofitted from corporate templates. We know your compliance requirements inside out and deliver clean audits that hold up when regulators come knocking.
• NFA Regulatory Compliance & Consulting: The NFA and CFTC don’t mess around, and neither do we. If you’re dealing with commodities, we’ll keep you compliant without the usual regulatory stress eating into your day.
• Tax Preparation: You can’t get anyone at the IRS on the phone right now. Good thing we already know how to handle your K-1s, performance allocations, and whatever complex structure you’re running.
• Audit, Tax, and Regulatory Support for Crypto Entities: Crypto just went from niche to normal overnight. If you’re trading, mining, or running a fund, we know the rules (even the ones they’re still writing).
• Industry-Specific Advisory: We’ve spent decades serving alternative investment firms, from hedge funds to private equity to real estate. Get personalized solutions from advisors who speak your language and understand your specific challenges.

Contact us today to learn more.