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Section 4(g)(6) of the Securities Exchange Act of 1934 (Exchange Act), 15 U.S.C. § 78d(g)(6), requires the

summary

The SEC's Office of the Investor Advocate released its FY 2025 Report on Activities, detailing efforts to combat investment fraud and improve retail disclosures.

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The report highlights the processing of 2,496 new investor matters by the Ombuds Office and the management of 27,000 individual contacts. Key initiatives included the launch of the Interagency Securities Council to coordinate with over 2,500 law enforcement representatives. While the report addresses rising fraud involving digital payments and cryptocurrency, it does not cite specific dollar amounts or individual defendants.

narrative

The SEC’s Office of the Investor Advocate (OIAD) published its Fiscal Year 2025 Report on Activities, outlining strategic efforts to protect investors and improve market transparency. The report details extensive engagement, including 120 activities and 27,000 individual contacts, alongside the analysis of over 250 SRO filings. Within the Ombuds Office, 2,496 new matters were processed, with an 11.62 percent increase in follow-up contacts to address issues like impersonation scams and fraud. To combat rising investment fraud facilitated by digital payments and cryptocurrency, the OIAD launched the Interagency Securities Council, connecting with over 2,500 law enforcement representatives. Additionally, the office focused on research regarding accredited investor status and the necessity of improved disclosures for 'Main Street' investors. The report emphasizes that while retail investment platforms offer benefits, they also necessitate more actionable and reliable disclosures to mitigate risks in private markets.

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Scheme
non-corporate (100%)
Victims
40
Classified non-corporate(confidence 100%). No EDGAR filing fingerprint (criminal/DOJ-side scheme). detection rule →
Statutes
15 U.S.C. § 78d(g)17 CFR § 230.501(a)Section 4(g)(6) of the Securities Exchange ActSection 4(g)(6) of the Securities Exchange ActSection 19(e) of the Securities Act
Parties
investor advocate
Keywords
investorinvestorsinvestor advocatesecreport activitiesadvocateactivitiesretail investorsreportfiscalcommissionombudssecuritiesretailactivities fiscal

Extracted insights

Dollar amounts 3
  • $1.00M $1 million $1M–$10M
  • $300K $300,000 $100K–$1M
  • $200K $200,000 $100K–$1M
Entities 1
  • person investor advocate
Triples 6
  • Investor Advocate file two reports per year with the Committee on Banking, Housing, and Urban Affairs of the Senate
  • Report on Objectives is due no later than June 30
  • Report on Activities is due no later than December 31
  • Report on Activities describes the activities of the Investor Advocate
  • Report on Activities expresses solely the views of the Investor Advocate
  • Commission disclaims responsibility for this Report on Activities
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Report on 
Activities
FISCAL YEAR 2025

ABOUT THIS REPORT AND DISCLAIMER
Section 4(g)(6) of the Securities Exchange Act of 1934 (Exchange Act), 15 U.S.C. § 78d(g)(6), requires the 
Investor Advocate to file two reports per year with the Committee on Banking, Housing, and Urban Affairs 
of the Senate and the Committee on Financial Services of the House of Representatives.
1
 The two reports 
are the mid-year Report on Objectives covering the forthcoming Fiscal Year and the end-of-year Report on 
Activities covering the preceding Fiscal Year.
A Report on Objectives is due no later than June 30 of each year, and its purpose is to set forth the objectives 
of the Investor Advocate for the following Fiscal Year.
2
 A Report on Activities is due no later than December 
31 of each year.
3
 The Report on Activities describes the activities of the Investor Advocate during the 
immediately preceding Fiscal Year. 
Disclaimer: Pursuant to Exchange Act Section 4(g)(6)(B)(iii), 15 U.S.C. § 78d(g)(6)(B)(iii), this Report on 
Activities is provided directly to Congress without any prior review or comment from the Commission, 
any Commissioner, any other officer or employee of the Commission outside of the Office of the Investor 
Advocate or the Office of Management and Budget. This Report on Activities expresses solely the views of 
the Investor Advocate. It does not necessarily reflect the views of the Commission, the Commissioners, or 
staff of the Commission, and the Commission disclaims responsibility for this Report on Activities and all 
analyses, findings, and conclusions contained herein.

REPORT ON ACTIVITIES: FISCAL YEAR 2025    |  iii
CONTENTS
MESSAGE FROM THE INVESTOR ADVOCATE   .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .1
FISCAL YEAR 2025 SUMMARY   .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .3
INVESTOR ENGAGEMENT   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .  4
Investor Engagement Activities   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .  4
SEC And External Collaboration   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .  6
FY 2025 by the Numbers   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .  6
Interagency Securities Council   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .  7
ADVOCACY FOR INVESTORS   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .  8
Private Markets   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .  8
Improving Disclosures for “Main Street” Investors   .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .8
Evaluating The Potential Impact of SRO Rule Proposals   .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .9
RESEARCH AND INVESTOR TESTING   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .10
THRIVE   .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .11
Accredited Investors   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .  11
MESSAGE FROM THE OMBUDS   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .13
ENDNOTES   .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .18
ERRATA SHEET   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .  20



REPORT ON ACTIVITIES: FISCAL YEAR 2025    |  1
MESSAGE FROM THE  
INVESTOR ADVOCATE
FOR THE PAST THREE YEARS, it has been my 
privilege to serve the public and the Commission 
as the Investor Advocate. When I accepted this 
honor back in January 2023, I did so with the 
intention of serving a limited term. In January 
2026, I will leave this role and the SEC in gratitude 
for the opportunity to promote the aspirations and 
confront the challenges of investors during a period 
of time when their choices have rapidly multiplied, 
as has the complexity of the decisions they make 
when investing their capital. 
During my tenure, I have often reiterated my belief 
that the expansion of retail investment products 
and platforms in the past few years is an overall 
benefit to individual investors, while also stressing 
the urgent need for better disclosures, especially 
as the complexity of products on offer grows. 
Free and fair markets cannot flourish without 
well-informed investors who can accurately 
compare risk and opportunity and apply market 
principles to their choices. 
The impact of retail investors on the markets 
overall has grown alongside the expansion of their 
investment opportunities, making the need for 
effective retail disclosures a subject worthy of every 
market participant’s attention. At the same time, 
information many institutional investors seek and 
receive is also evolving, intensifying the focus on 
what it means to give and receive disclosures. 
Actionable and reliable disclosure is not only 
critical for informed investment decisions, it is 
necessary for sound policy development. As an 
undergraduate, I took a class with Edward Tufte 
on producing and evaluating data and statistical 
analyses for policymaking which continues to 
influence my thinking to 
this day. Sound policy 
depends on seeking 
answers to unbiased 
questions in the world 
as it is, not as we wish it 
to be.
I have endeavored to 
strengthen the investor 
research program that 
my predecessor, Rick 
Fleming, established 
when he organized the Office of the Investor 
Advocate. During my tenure, we have launched 
the production of quarterly, longitudinal data sets 
that can provide reliable, consistent, and timely 
information about retail investor behavior to the 
Commission and rule-writing teams. We have 
also maintained the ability to engage more deeply 

2    |  OFFICE OF THE INVESTOR ADVOCATE
with investors to conduct qualitative testing and 
data collection that can inform policy making, and 
expanded our direct engagement with investors 
with different viewpoints and experiences.  
I am very grateful to Chairman Atkins and 
Commissioners Peirce, Crenshaw, and Uyeda for 
their encouragement and on-going support of 
the work of our office, especially our research. I 
hope that the data we have produced continues 
to be of service in evaluating the policy choices 
the Commission makes. I am also grateful to the 
Investor Advisory Committee, on which I have 
served as a statutory member. The volunteer 
members of the IAC give generously of their time 
and talent to provide the Commission with valuable 
insights and thoughtful recommendations.
Finally, I want to acknowledge the SEC staff, 
especially those in the Office of the Investor 
Advocate. Their dedication, expertise, and 
professionalism is a credit to the investors they 
serve, and is reflected in the legal analysis, 
engagements, and assistance they offer. In 
particular, I would like to thank Marc Sharma, 
Lisa Skrzycki, Alycia Chin, Katie Carman, Adam 
Anicich, and Andrew Sporkin, who is retiring after 
nearly four decades of service with the SEC. I have 
learned from them every day of my tenure, and I 
am proud to have been their colleague.
I am pleased to submit this Report on Activities 
for Fiscal Year 2025 on behalf of the Office of the 
Investor Advocate, and I welcome any questions 
from Members of Congress.
Respectfully Submitted,
CRISTINA BEGOÑA MARTIN FIRVIDA 
Investor Advocate 

REPORT ON ACTIVITIES: FISCAL YEAR 2025    |  3
FISCAL YEAR 2025  
SUMMARY
120
ENGAGEMENT 
ACTIVITIES
2,496
INVESTOR SUBMISSIONS 
to the Ombuds
DATA COLLECTION  
ACTIVITIES
involving 
over
INDIVIDUAL INVESTOR 
CONTACTS
27,000
14
RULEMAKINGS and 
STAFF STATEMENTS 
reviewed
250+
SRO FILINGS  
reviewed

4    |  OFFICE OF THE INVESTOR ADVOCATE
INVESTOR ENGAGEMENT
T
he Office of the Investor Advocate 
(OIAD) is statutorily mandated to assist 
retail investors, identify problems that 
investors may have, analyze the potential 
impacts on investors of rules or regulations, and 
make proposals to the Commission to promote the 
interests of investors.
4 
One of the primary ways in which OIAD collects 
this information and sustains a focus on investors 
is through ongoing investor engagement activities,
5
 
which directly support the statutory mandate and 
help amplify the voices of investors.
INVESTOR ENGAGEMENT ACTIVITIES
The Office actively seeks input from a broad range 
and variety of investors—including individual retail 
investors, smaller and regional investor groups, 
non-profits and consumer groups, academics and 
FIGURE 1. Investor Groups Consulted
OIAD 
Engagement
Retail  
Investors
Financial Industry 
Representatives
Students and Young 
Professionals
Businesses and 
Capital Seekers
Pension Plans and 
Public Retirement 
Systems
Academic and 
Advocacy Groups
Legal 
Representatives
Institutional 
Investors
Law Enforcement and 
Other Government 
Agencies

REPORT ON ACTIVITIES: FISCAL YEAR 2025    |  5
researchers, public and private pension funds, and 
other small and large money managers—as well as 
regulatory and law enforcement counterparts.
6
Retail investors, and their unique perspectives, 
are particularly important to OIAD. We place 
special emphasis on individuals and groups whose 
views and needs may be less frequently heard, 
including those who do not routinely travel to 
Washington, DC, to lobby government leaders, or 
who do not regularly submit comment letters to the 
Commission. Among those whom OIAD especially 
seeks to hear from are older investors, new 
investors, veterans, military, and military spouses, 
affinity-connected investors, investors from rural 
and non-metro areas, historically underserved 
and/or Native American communities, crypto and 
non-traditional finance investors, investors with 
disabilities, investors with innovative approaches 
to investing, and investors with varying levels of 
exposure to capital markets. The Office also solicits 
and encourages input from stakeholders with a 
range of epistemological perspectives and values. 
The goals for investor engagement are twofold: 
 ƒUnderstand investor experiences and 
perspectives regarding products, practices, 
regulations, rulemakings, and the markets, and 
communicate them in a decision-useful context 
for Commission leaders and staff; and 
• Advocate for investors’ interests in the 
regulatory and rulemaking environments 
in a manner consistent with the Office’s 
statutory mission.
This year, the Office continued to meet with 
a broad array of investors and investor 
representatives to gain from their perspectives and 
identify trends, issues, and policies that investors 
consider to be important. By leveraging virtual 
conferencing, in addition to the numerous in-person 
activities traditionally performed, OIAD welcomed 
a number of new investors and related groups to 
share their experiences with the Investor Advocate.
7
One area in which OIAD further matured this year 
was to increase engagement with State and Local 
government agencies, as well as expand data-driven 
decision-support across the portfolio, which 
provided decision makers with useful and evidence-
based investor preferences, trends, and capabilities. 
OIAD has the unique ability to identify, answer, 
evaluate, and operationalize the questions of: 
 ƒWhat do we learn from investors? 
• What do we do with that information? 
OIAD does this, in part, by partnering with 
other Divisions and Offices to hear directly from 
investors regarding the impact that potential rules 
FIGURE 2. Types of Investor Engagement
PHASE 1
Active listening
PHASE 2
Research and  
data analysis
PHASE 3
Collaboration and 
partnerships
PHASE 4
Decision-useful 
feedback to SEC 
leaders
PHASE 5
Integration into 
SEC Policies and 
Practices

6    |  OFFICE OF THE INVESTOR ADVOCATE
and regulations have on investors and identify 
problems that investors may have with products 
or services. The goal is to further institutionalize 
stakeholder (i.e., investor) input into all stages of 
the Commission’s operations.
SEC AND EXTERNAL COLLABORATION
OIAD further enhanced available engagement 
opportunities with other SEC Divisions and 
Offices, federal departments, state agencies, and 
law enforcement partners—so that they could hear 
directly from investors how the Commission, and 
the government, can best serve them. This included:
SEC Divisions and Offices 
The Office expanded opportunities for investors 
to communicate their perspectives directly with 
the Divisions. For example, during FY 2025, 
OIAD organized numerous investor engagement 
activities with Division and Office Directors 
and Commissioners, so they could hear investor 
commentary first-hand—including hosting an event 
titled Demystifying Capital Markets and the SEC’s 
Investor Advocacy Law School Clinic Summit. 
Federal Departments and Agencies 
In addition to the SEC, other federal departments 
and agencies are constantly working to protect 
the financial markets, products, and the American 
people. As part of the Office’s regular course of 
business, we often communicate and partner with 
federal agencies to support the larger investor 
advocacy mission, or to obtain broad investor 
and stakeholder feedback consistent with our 
statutory mission. 
State Agencies 
State Securities Regulators play a critical part in 
the regulatory and investor protection mosaic, and 
the Office continued to foster the already strong 
connections with the North American Securities 
Administrators Association (NASAA) and 
individual state regulators. 
Law Enforcement Partners 
As part of OIAD’s commitment to investors, 
understanding the evolution in investment frauds 
is of paramount concern. To enhance the Office’s 
ability to mitigate problems and promote the 
interests of investors, the Division of Enforcement 
in 2024 launched the Interagency Securities 
Council
8
 (ISC), with OIAD’s conceptualization 
and support. The ISC convenes recurring meetings 
between law enforcement and regulators at the 
federal, state, and local levels. Additional details 
are described in the Interagency Securities Council 
section below. 
OIAD also engaged with various local, state, 
and federal law enforcement and government 
regulatory agencies throughout the year to better 
understand the threats facing retail investors, and 
the related feedback from investors that other 
agencies are receiving. 
FY 2025 BY THE NUMBERS
OIAD hosted or substantially contributed to 
approximately 120 engagements in FY 2025, 
with one-third of those being individuals or 
organizations that had not previously met with 
the Office.
9
 Through these engagements, investors, 
firms, advocates, investigators, and regulators 
shared their experiences with investment products 
and providers, policy, rules, and regulation, the 
SEC and SROs, and securities fraud. 
These engagements directly informed the Investor 
Advocate’s consultations with the Chairman and 
Commissioners, Division and Office directors, 
and senior staff related to the experiences of 
everyday American investors, as well as the two 
annual reports the Office develops and submits to 
Congress, pursuant to statute.
10
 
The Office also presented at multiple large 
conferences, including SEC Speaks,
11
 the ICGN 
30th Anniversary Conference in the Americas, the 

REPORT ON ACTIVITIES: FISCAL YEAR 2025    |  7
2025 CIPHER Conference, and the PwC Fraud 
Executive Roundtable. 
INTERAGENCY SECURITIES COUNCIL
The Interagency Securities Council (ISC)
12
 is a 
joint task force that invites federal, state, and local 
regulatory and law enforcement professionals to 
meet quarterly to discuss the latest in scams, trends, 
frauds, and mitigation strategies, and provides 
briefings on emerging and complex topics.
The ISC’s objective is to strengthen the cohesion 
between federal, state, and local agencies, enhance 
opportunities to collaborate on cases to protect 
investors, provide insight and guidance across the 
ecosystem for investigators who may not frequently 
operate in the securities space, and creates a 
forum for unified efforts in combating financial 
fraud. Chaired by the Director of the Division 
of Enforcement, OIAD’s Investor Engagement 
Manager envisioned, developed, and leads the 
SEC’s efforts on the Council.
This unique Council is limited to law enforcement 
and government regulatory agencies, and now 
includes over 2,500 representatives from more than 
250 departments and agencies,
13
 including federal 
financial and law enforcement agencies, state 
offices of attorneys general and state police, state 
securities regulators, and local police departments 
and sheriff’s offices. Members participate in 
discussions with experts on emerging threats, hear 
from investigators conducting and supervising 
investigations, and explore case study examples 
of agencies employing innovative approaches to 
combat financial fraud. The ISC also serves as 
an opportunity to connect and share information 
with the larger law enforcement community that 
less frequently deals with securities law violations, 
such as police/sheriff departments and tribal- and 
military-community law enforcement.
In FY 2025, the ISC conducted large meetings
14
 
and hosted specialized briefings with experts, 
such as a briefing on Digital Evidence Collection, 
Extraction, and Preservation with the SEC’s Office 
of Inspector General. 
The ISC was also invited by SEC’s Investor 
Advisory Committee to present on threats facing 
retail investors at the public meeting
15 
 in March 
2025; with the presentation later being cited
16
 
in others’ congressional testimony, and the 
Congressional Record. 
FIGURE 3. Number of Engagements
FY 2022
72
FY 2023
142
FY 2024
112
FY 2025
120
FY 2021
88

8    |  OFFICE OF THE INVESTOR ADVOCATE
ADVOCACY FOR INVESTORS
T
his section of our annual Report on 
Activities describes a selection of our 
policy activities on behalf of investors 
for the period from October 1, 2024 
through September 30, 2025 (the Reporting Period).
PRIVATE MARKETS
During Fiscal Year 2025, the Office of the Investor 
Advocate continued to pay close attention to 
the issues surrounding the considerable growth 
of the private markets in the United States over 
the past two decades. In our prior Reports, we 
have acknowledged that the private markets have 
become an increasingly important avenue both for 
companies seeking to raise capital and for investors 
seeking investment opportunities and portfolio 
diversification. We also recognize the risks inherent 
in investing in the private markets, including 
reduced, incomplete or unreliable disclosure; 
limited liquidity; and greater risk of fraud and/or 
investment loss.
A key element of this effort has been our 
ongoing outreach to institutional and retail 
investors and other stakeholders to acquire a 
deeper understanding of the issues and different 
perspectives surrounding the private markets. 
Through this outreach, we have gained further 
insight into, and developed a greater appreciation 
of, the range of views held by investors and other 
stakeholders on topics such as expanded retail 
investor participation in the private markets, 
the inclusion of private market investments 
in retirement savings plans, the degree of 
transparency in the private markets, accredited 
investor status, and the interplay between the 
private and public markets.
17
The Office has also continued to monitor pending 
legislative proposals in Congress that addressed 
various aspects of the private markets and 
evaluated the impact that these bills would have 
on investors. In addition, our Office of Investor 
Research (OIR) has engaged in ongoing research 
on topics relating to the private markets, which 
included the issuance of a working paper on 
accredited investors and private market securities 
ownership in June 2025.
18
Chairman Paul Atkins has indicated that 
democratizing access to alternative assets and 
facilitating the ability of retail investors to 
participate in the private markets, consistent with 
President Trump’s Executive Order,
19
 is a priority 
for the Commission. Going forward, we will 
continue to focus on the issues surrounding the 
private markets and will endeavor to help ensure 
that investors’ interests remain at the forefront 
of the discussion as the Commission considers 
potential initiatives in this area.
IMPROVING DISCLOSURES FOR 
“MAIN STREET” INVESTORS
Another longstanding area of focus in the Office 
of the Investor Advocate has been the quality and 
effectiveness of disclosures provided to investors, 
particularly retail investors. Over the years, the 
Office has been supportive of the Commission’s 
efforts to assess and improve the efficacy of 
disclosures by public companies, investment 
companies, and other regulated entities. Among 
other things, we have encouraged investor testing 
as a means of improving the accessibility of 
disclosures to retail investors, as our Office of 
Investor Research has moved forward with its 

REPORT ON ACTIVITIES: FISCAL YEAR 2025    |  9
innovative research efforts on investor behavior 
and decision making.
Many commentators have noted the increasing 
length and complexity of the disclosures being 
provided under the Commission’s rules and have 
raised concerns as to whether material information 
is communicated to investors under these rules in 
a more effective manner. During the Reporting 
Period, the Office sought to develop a more 
thorough understanding of how investors use 
these disclosures and to solicit a range of views on 
how to improve the effectiveness of the current 
disclosure system. Through ongoing engagements 
with retail investors and other relevant parties 
as well as our own analysis, the Office gained 
additional insight on different approaches to 
making required disclosures more user-friendly 
and comprehensible to investors, particularly retail 
investors, while also taking into account the extent 
to which this may add to the costs and burdens on 
issuers and other providers of disclosure.
According to the Commission’s most recent 
Regulatory Flexibility Act Agenda, Commission 
staff is considering rule amendments to “rationalize 
disclosure practices to facilitate material disclosure 
by companies and shareholders’ access to that 
information.” We welcome staff recommendations 
that would make disclosures more accessible to 
retail investors in a cost-effective manner, and we 
will continue to monitor developments in this area, 
including the increasing use of artificial intelligence 
in both preparing and analyzing disclosures, as we 
advocate for the disclosure needs of investors.
EVALUATING THE POTENTIAL IMPACT 
OF SRO RULE PROPOSALS
Pursuant to our statutory mandate, during 
Fiscal Year 2025, the Office of the Investor 
Advocate continued to analyze the potential 
impact on investors of proposed rules of SROs. 
Self-regulation of market intermediaries is a core 
element of the securities law framework concerning 
national exchanges, broker-dealers, and clearing 
agencies. These SROs are primarily responsible 
for establishing the standards under which their 
members conduct business and for monitoring that 
conduct; and can do so in ways that are innovative 
and fast moving. Due to potential conflicts of 
interest in their business models, however, SEC 
oversight of the SROs is an important component—
both to instill public confidence in the securities 
industry and to ultimately protect investors. During 
Fiscal Year 2025, our resources allowed our Office 
to analyze over 250 of the proposed rules of SROs. 
In Fiscal Year 2026, the Investor Advocate will 
continue to communicate with investors and their 
representatives to determine the potential impact of 
proposed rules of SROs on investors and consider 
areas in which investors could benefit from changes 
in the proposals.

10    |  OFFICE OF THE INVESTOR ADVOCATE
RESEARCH AND 
INVESTOR TESTING
T
he Exchange Act directs the Investor 
Advocate to identify problems with 
financial service providers and 
investment products and analyze 
the potential impact on investors of proposed 
regulations of the Commission and proposed rules 
of self-regulatory organizations. Pursuant to Section 
4(g)(3) of the Exchange Act, the Investor Advocate 
created OIAD’s Office of Investor Research (OIR) 
to accomplish these goals. Pursuant to Section 4(g)
(6) of the Exchange Act, OIAD summarizes OIR’s 
activities annually in its Report on Activities for 
Fiscal Year.
OIR is a multidisciplinary group that uses investor 
testing, surveys, qualitative interviews, and 
statistical modeling to study investment behavior 
and provide the Commission and the public with 
insight into how investors and other stakeholders 
interact with the investment marketplace. OIR 
provides research support to Commission offices 
and divisions seeking objective information about 
investors and responds to Congressional mandates 
for investor testing.
20
 Section 19(e) of the Securities 
Act, in addition to other statues, authorizes OIR to 
conduct investor testing.
OIR conducts long-term research to understand 
fundamental aspects of investor behavior and 
works with policymakers to provide an evidence 
base for policymaking. Since June 2017, OIR has 
conducted 79 survey and experimental projects, 
19 qualitative data collection projects, and several 
analyses of market data, including 8 surveys and 1 
qualitative data collection project in this fiscal year. 
OIR’s research has been published in peer-reviewed 
journals including the Journal of Economic 
Behavior & Organization and Financial Services 
Review, and cited in multiple SEC rulemakings.
21 
In 
Fiscal Year 2025, OIR also presented research at 
the Current Innovations in Probability-Based 
Household Internet Panel Research (CIPHER) 
conference in an effort to promote investor-related 
research within the broader scientific community.
Looking forward, OIR will continue to support 
OIAD’s statutory directive through high-quality 
research. We intend to examine investors’ decisions 
and behavior, their decision context, household 
factors, and macroeconomic trends. The rest of this 
year’s report presents a subset of results from OIR’s 
public research.
1979
qualitativequantitative

REPORT ON ACTIVITIES: FISCAL YEAR 2025    |  11
THRIVE
OIR directs and maintains a nationally 
representative survey panel of U.S. retail investors 
referred to as the Thoughtful Households Relating 
InVesting Experiences (THRIVE) Panel. THRIVE 
consists of quarterly longitudinal surveys (that is, 
surveys that invite the same people over time) and 
custom testing projects that are the Commission’s 
primary research tool for understanding retail 
investors. As part of THRIVE quarterly surveys, 
7,500 people are invited to answer recurring 
questions on investment decisions and household 
events, as well as novel questions examining 
contemporaneous areas of interest.
THRIVE benefits the Commission and OIAD 
in multiple ways. Longitudinal surveys are a 
cost-effective and efficient method for evaluating 
key investor developments and identifying 
emerging investor issues, information that is 
critical to understanding investor activity, and 
promoting policy efficacy. Each quarter, OIR 
produces Perspectives on Investing in the U.S.: 
Insights from THRIVE, which contains 9 key 
measurements from each quarterly survey.
THRIVE also provides infrastructure that allows 
OIAD to quickly respond to policymakers’ needs 
by reducing the cost and time required to collect 
data. We discussed additional benefits of THRIVE 
in our 2024 Report on Activities.
22
 
ACCREDITED INVESTORS
Accredited investors include individuals and entities 
that meet certain criteria thought to be indicative 
of financial sophistication or the ability to bear 
financial risk, such as meeting a net worth or 
income threshold or holding certain professional 
certifications or designations. Individuals and 
entities that qualify as accredited investors may 
participate in investment opportunities such as 
private offerings conducted by issuers relying on 
Rule 506 of Regulation D.
Four ways for individuals to qualify as an 
accredited investor include (1) having a net worth 
or joint net worth with a spouse of over $1 million, 
excluding their primary residence; (2) having 
individual income that exceeds $200,000 in 
each of the prior two years and a reasonable 
expectation of that income level in the current year; 
9.7%2.8%2.8%1.7%
Household 
Net Worth
Personal 
Income
Household 
Income
Specialized
Expertise
FIGURE 4. The percentage of the U.S. population that qualifies as accredited investors by criteria

12    |  OFFICE OF THE INVESTOR ADVOCATE
(3) having joint income (with a spouse or spousal 
equivalent) that exceeds $300,000 in each of the 
prior two years and a reasonable expectation of 
that income level in the current year; or (4) holding 
certain professional certifications or other 
credentials (e.g., the Series 65 investment adviser 
representative license).
23
 
This year, OIAD was interested in better 
understanding the characteristics and capabilities 
of accredited investors. OIR conducted research 
in furtherance of this goal by analyzing nationally 
representative survey data from THRIVE to 
document the characteristics of accredited investors 
and non-accredited investors.
24
 
Based on our research, we find that 12.6% of 
individuals in the U.S. population qualify as 
accredited investors. Individuals primarily qualify 
based on their reported net worth (capturing 9.7% 
of the population), followed by personal income 
(capturing 2.8% of the population) and household 
income (capturing 2.8% of the population). 
Least common is qualifying based on specialized 
expertise (capturing 1.7% of the population). The 
majority of accredited investors (75%) satisfy only 
a single criterion, while the remaining 25% satisfy 
two or more. 4.3% of those who qualify report 
owning private market securities described in the 
question as “private funds or offerings” and further 
specifying that these types of assets typically require 
investors to meet certain criteria.

REPORT ON ACTIVITIES: FISCAL YEAR 2025    |  13
MESSAGE FROM  
THE OMBUDS
There are some frauds so well conducted, that it 
would be stupidity not to be deceived by them.
25
 
THE OMBUDS OFFICE data reported below 
indicates that, statistically, every single day, an 
Ombuds staff member responds to an investor 
defrauded in an investment scheme. Nearly 
all of the fraud complaints reported to the 
Ombuds Office during the Reporting Period were 
made possible by digital payment services or 
cryptocurrency platforms, encrypted messaging 
systems, and the investor’s lack of information 
and experience with legitimate cryptocurrency 
investments. In this void of information, scammers 
exploit ignorance, oftentimes funneling Americans’ 
hard-earned savings out of the country and into the 
coffers of organized crime. 
Too many investors do not know legitimate 
financial professionals do not communicate 
via Instagram or WhatsApp. Investors may 
not understand why they should not fund an 
investment account by digital payments to a 
third party. Investors too often believe that an 
application available for download through their 
smartphone’s official system means it has been 
approved by the distributor and is safe. When 
sophisticated scammers impersonate legitimate 
firms, financial professionals, and government 
employees, how are Main Street investors expected 
to know the difference? 
When the staff of the Ombuds Office responds to 
defrauded investors, we have no trouble finding 
publications from the SEC and other agencies 
providing education about investing and warning 
against fraud tactics. Unfortunately, these resources 
are often identified all too late. 
During my time at the SEC providing direct 
investor assistance, I’ve 
observed my colleagues 
at the SEC and other 
agencies use every tool 
at their disposal to 
address investment fraud. 
Often jurisdictional and 
resource roadblocks 
hamper efforts to hold 
wrongdoers accountable 
or return lost funds; 
however, I am heartened 
by the successes of recent 
agency and interagency actions targeting the 
organizations allegedly responsible for much of 
the fraud reported to our office. As our previous 
Ombuds warned in last year’s Report on Activities, 
without necessary funding for law enforcement and 
regulatory agencies, we may fail to quell this rising 
tide of fraud.
26
 
I reiterate the prior Ombuds’ plea to Congress to 
provide the SEC, other financial regulators, and 

14    |  OFFICE OF THE INVESTOR ADVOCATE
law enforcement agencies the necessary funds 
to address this fraudulent activity.
27
 Otherwise, 
agencies like the SEC are forced to divert resources 
away from our other investor protection efforts or 
risk failing to respond at all. In my observation, 
more often than not, it is the SEC frontline staff 
that shoulders this burden, drawing upon a selfless 
devotion to the agency’s mission to bridge the gap 
between what we have to work with and what 
must be done.
Our nation cannot afford to watch the savings and 
investment accounts of Americans continue to be 
raided by foreign bad actors. 
***
It has been one of the highest honors of my career 
to head the Ombuds Office during this period of 
transition and to be able to escalate the concerns 
of retail investors to the Commission’s senior 
leadership. I am humbled by the trust placed in 
me by the Investor Advocate and the Ombuds 
Office staff.
As the term of my temporary appointment to 
Acting Ombuds comes to an end in January 2026, 
I look forward to rejoining my colleagues as a 
staff attorney and supporting the goals of the next 
Investor Advocate and their appointed Ombuds. 
Finally, I extend my gratitude to the staff of the 
Ombuds Office for their steadfast commitment 
and enthusiasm in serving retail investors, and my 
colleagues in the Office of the Investor Advocate 
and across the SEC for their support of our work. 
Above all, I thank the Investor Advocate, Cristina 
Martin Firvida, for her leadership, support, and 
unwavering dedication to retail investors for the 
last three years.
Respectfully Submitted, 
LISA A . SKRZYCKI 
Acting Ombuds

REPORT ON ACTIVITIES: FISCAL YEAR 2025    |  15
WHO WE ARE 
The Securities Exchange Act requires the Investor 
Advocate to appoint an Ombudsman (Ombuds) 
to act as a liaison for retail investors to relay their 
concerns and questions about the Commission 
and the self-regulatory organizations (SROs) the 
Commission oversees.
28
 The Ombuds staff consists 
of an experienced team of lawyers, law clerks, 
and paralegals, each with differing subject matter 
expertise, all dedicated to providing personalized, 
tailored assistance to the retail investors that 
contact the Ombuds Office for help. Through 
direct engagement with investors, relevant parties 
within the Commission, and external stakeholders 
committed to investor protection issues, the 
Ombuds Office fulfills its statutory duty to help 
retail investors resolve issues relating to the 
Commission and SROs.
Among other statutory duties, the Ombuds must 
submit biannual reports to Congress describing the 
work of the office and its effectiveness in assisting 
retail investors.
29
 This Ombuds’ Report provides 
a look back on the Ombuds’ activities for the 
twelve-month period of October 1, 2024, through 
September 30, 2025 (Reporting Period), and 
discusses the Ombuds’ objectives and outlook for 
Fiscal Year 2026.
WHAT WE DO 
As noted above, the Ombuds is required by 
statute to: 
 ƒhelp retail investors resolve questions and 
complaints they may have with the Commission 
or with SROs the Commission oversees; 
 ƒreview and make recommendations regarding 
policies and procedures that encourage investors 
to present questions to the Investor Advocate 
regarding compliance with the securities laws; 
 ƒtake steps to ensure the confidentiality of 
investor communications with our Office; and 
• submit biannual reports to the Investor 
Advocate that describe the activities and 
evaluate the effectiveness of the Office.
30
 
HOW WE HELP 
Our primary responsibility is to assist retail 
investors by resolving concerns, questions, 
and complaints about the SEC and the SROs 
subject to SEC oversight. We accomplish this in 
several ways—most commonly by conducting 
research, providing information, making referrals, 
conducting research, and collaborating with other 
divisions, offices, and SROs about complaints that 
impact investor interests. 
Many submitters who contact our Office are 
not complaining about the SEC and SROs, but 
rather seek assistance and information regarding 
fraud. When we receive credible allegations of 
securities violations, we refer this information to 
the Divisions of Examinations and Enforcement 
for potential examination, investigation, or 
action. When we receive reports of fraudsters 
impersonating the SEC or misappropriating the 
SEC’s seal, we notify staff in the Office of the 
General Counsel and Office of Inspector General. 
If an investor seeks assistance with their personal 
investments or an investment account, we refer the 
investor to the Office of Investor Education and 
Advocacy. In all cases, we endeavor to make sure 
the investor receives a clear response from the SEC 
regarding their concerns and that such concerns are 
elevated to the attention of the Investor Advocate 
and other interested parties within the Commission. 

16    |  OFFICE OF THE INVESTOR ADVOCATE
Review
The Ombuds team reviews all incoming investor 
correspondence to determine if and how we may assist .
FIGURE 5. The Process by Which We Receive and Assist Investors with Their Requests 
Research
The Ombuds team identifies the nature of the issue, conducts 
tailored research, and engages with appropriate personnel 
within the Commission or SROs to gather relevant information .
Resolve
The Ombuds team works to resolve investor 
questions and complaints by providing 
investors with requested information and 
access to additional resources, by escalating 
certain matters through appropriate channels, when 
necessary, and by monitoring outcomes .
HOW TO CONTACT US 
Our primary means of communication with 
the public is through the Ombudsman Matter 
Management System (OMMS), an online portal 
for receiving, responding to, and managing data 
submitted to our Office. The public can also 
contact us by email, telephone, and regular mail. 
INVESTOR VOICES, BY THE NUMBERS 
The Ombuds team maintains 
records in OMMS of all submissions 
and responses handled by our 
Office. Matters are assigned a label 
or “Primary Issue Category,” reflecting the nature 
of the issues raised in the submission.
31
 
In tracking investor submissions by volume and by 
Primary Issue Category, OMMS may serve as an 
early warning system, flagging existing or potential 
risks for retail investors.
During the Reporting Period (October 1, 2024 –  
September 30, 2025), the Ombuds Office received 
and processed 2,496 new matters submitted by 
U.S. and foreign investors, market participants, and 
other interested members of the public. (Matters 
counted in prior reports and reopened during 
the Reporting Period are not reflected in this 
figure.) The chart below (Figure 6) illustrates the 
number of matters divided into 12 Primary Issue 
Categories, which are used to classify the nature of 
the submission.
In addition, the Ombuds team made approximately 
3,784 follow-up emails, phone calls, and other 
forms of correspondence to resolve the 2,496 
matters received and reopened matters identified in 
prior reports. This accounts for a combined total of 
6,280 contacts with or on behalf of submitters from 
October 1, 2024 to September 30, 2025. Figure 7 
details the number of follow-up contacts, separated 
by Primary Issue Category. 

REPORT ON ACTIVITIES: FISCAL YEAR 2025    |  17
In comparison to the figures reported in FY 2024, 
the Ombuds Office has noted a slight decrease 
in the volume of new matters submitted to the 
Ombuds Office, along with a slight increase in the 
team’s efforts to resolve these matters. The total 
number of matters received in FY 2025 (2,496) 
decreased by approximately 9.96 percent from 
FY 2024 (2,772). The total number of contacts in 
FY 2025 (3,784) marked an approximate increase 
by 11.62 percent from the number of contacts in 
FY 2024 (3,390). 
FIGURE 6. Matters by Primary Issue Category, 
October 1, 2024 – September 30, 2025
Allegations of securities law violations (370)
Atypical matters (348)
Inquiries about corporate disclosure/ 
registration (53)
FINRA complaints/questions/procedures (76)
Investor account matters (439)
Investment products-questions/complaints (92)
Non-SEC/other matters (266)
SEC Investigations/litigation/enforcement  
actions (220)
SEC/other impersonators (116)
Other SEC questions/complaints (452)
Other SRO complaints (46)
Potential organized campaign (18)
Total 2,496  
FIGURE 7. Contacts by Primary Issue 
Category, October 1, 2024 – September 30, 
2025
Allegations of securities law violations (717)
Atypical matters (80)
Inquiries about corporate disclosure/ 
registration (94)
FINRA complaints/questions/procedures (141)
Investor account matters (809)
Investment products-questions/complaints (136)
Non-SEC/other matters (330)
SEC investigations/litigation/ 
enforcement actions (410)
SEC/other impersonators (294)
Other SEC questions/complaints (670)
Other SRO complaints/questions/procedures (85)
Potential Organized Campaign (18)
Total 3,784  
9%
5%
15%
14%
18%
4%
11%
18%
2%
3%
2%1%
21%
11%
8%
19%
3%
4%
4%
9%
18%
2%
2%
0.5%

18    |  OFFICE OF THE INVESTOR ADVOCATE
ENDNOTES
1 Exchange Act § 4(g)(6), 15 U.S.C. § 78d(g)(6).
2 Exchange Act § 4(g)(6)(A)(i), 15 U.S.C. § 78d(g)(6)
(A)(i).
3 Exchange Act § 4(g)(6)(B)(i), 15 U.S.C. § 78d(g)(6)
(B)(i).
4 See Exchange Act § 4(g)(4), 15 U.S.C. § 78d(g)
(4). Full text is available at https://www.govinfo.
gov/content/pkg/COMPS-1885/pdf/COMPS-1885.
pdf#page=57.
5 See SEC’s Performance Goal #6: Investor Engagement 
Activities, SEC, Fiscal Year 2026 Congressional 
Budget Justification Annual Performance Plan 
Fiscal Year 2024 Annual Performance Report 
(May 30, 2025), https://www.sec.gov/files/fy-2026-
congressional-budget-justification.pdf#page=55.
6 Investor Engagement Activities are defined in the 
SEC’s performance goals as organizing: “investor-
focused meetings, events, and activities that are 
designed primarily to engage directly with investors 
and receive feedback about policy questions, investing 
challenges, regulatory policy and rulemaking, 
investment products and services, investor issues, 
and/or potential misconduct. Investor Engagement 
Activities, defined above, include consultations 
with individual investors; small business investors; 
institutional investors; representatives from 
organizations that are comprised of, and/or represent 
the interests of, investors; other market participants 
and industry experts, and law enforcement and 
regulatory entities. This also includes a number of 
public events such as investor roundtables, public 
meetings, and academic engagement.”
7 OIAD conducted investor engagement activities with 
approximately forty new entities/organizations in 
fiscal year 2025.
8 See Press Release, SEC, SEC Launches Interagency 
Securities Council to Coordinate Enforcement 
Efforts Across Federal, State, and Local Agencies 
(July 19, 2024), https://www.sec.gov/newsroom/press-
releases/2024-86.
9 Approximately 40 Investor Engagement Activities 
in FY 2025 were classified as “new engagements”—
those that included individuals or organizations that 
had not previously consulted or engaged with the 
Office of the Investor Advocate.
10    Pursuant to 4(g)(6)(A)(i) and (B)(i) of the Exchange 
Act, the Investor Advocate is required to submit to 
the Committee on Banking, Housing, and Urban 
Affairs of the Senate and the Committee on Financial 
Services of the House of Representatives the following 
two reports each year: (1) a report on the objectives 
of the Investor Advocate for the following fiscal year, 
not later than June 30 each year; and (2) a report 
on the activities of the Investor Advocate during 
the immediately preceding fiscal year, not later than 
December 31 each year.
11    Additional details and the full agenda for Practising 
Law Institute’s SEC Speaks event can be found 
online at https://www.pli.edu/programs/the-sec-
speaks/413804.
12 See Press Release, SEC, SEC Launches Interagency 
Securities Council to Coordinate Enforcement 
Efforts Across Federal, State, and Local Agencies 
(July 19, 2024), https://www.sec.gov/newsroom/press-
releases/2024-86.
13    As of September 30, 2025.
14    The term “large meetings” generally indicates multiple 
hundreds of law enforcement and government 
regulators from one-to-two hundred departments and 
agencies all over the country.
15    Details and the full agenda can be found at https://
www.sec.gov/about/advisory-committees/investor-
advisory-committee/iac030625-agenda.
16 See Financial Aggression: How The Chinese 
Communist Party Exploits American Retirees and 
Undermines National Security, U.S. Senate Special 
Committee and the U.S. House Select Committee on 
the Chinese Communist Party, 119th Cong. (2025)
(statement of Christopher Iacovella, President and 
CEO, American Securities Association), https://www.
congress.gov/event/119th-congress/senate-event/
LC74495/text.
17    This range of views is reflected in a wide array of 
recent policy recommendations from various parties 
on improving private market regulation, including 
a recommendation issued by the Investor Advisory 
Committee at its September 2025 meeting on retail 
investor access to private market assets.
18 See Katherine Carman et al., Exploring Accredited 
Investors and Private Market Securities Ownership 
(SEC, OIAD Working Paper No. 1, 2025), 
https://www.sec.gov/files/exploring-accredited-
investors-june-2025.pdf.

REPORT ON ACTIVITIES: FISCAL YEAR 2025    |  19
19    Exec. Order No. 14330, 90 FR 38921 (Aug. 12, 
2025), https://www.whitehouse.gov/presidential-
actions/2025/08/democratizing-access-to-alternative-
assets-for-401k-investors.
20 See, e.g., U.S. House of Representatives, Consolidated 
Appropriations Act, H.R. 2617, Pub. L. No. 117-328, 
136 Stat. 5529 (2022), https://www.congress.gov/
bill/117th-congress/house-bill/2617 (Sec. 101(b)(2)(B) 
directing the Commission to conduct investor testing 
on registered index-linked annuities).
21 See Alycia Chin et al., How Should I Know? Lack 
of Confidence Biases Stock Market Expectations 
Toward Zero, 229 Journal of Economic Behavior 
& Organization (2025); see also Brian Scholl et al., 
Mutual Fund Knowledge Assessment for Policy and 
Decision Problems, Financial Services Review (2022); 
see also SEC, Registration for Index-Linked Annuities 
and Registered Market Value Adjustment Annuities; 
Amendments to Form N-4 for Index-Linked 
Annuities, Registered Market Value Adjustment 
Annuities, and Variable Annuities; Other Technical 
Amendments, 89 Fed. Reg. 59978 (Jul. 24, 2024); see 
also SEC, Tailored Shareholder Reports for Mutual 
Funds and Exchange-Traded Funds; Fee Information 
in Investment Company Advertisements, 87 Fed. Reg. 
72758 (Nov. 25, 2022); see also SEC, Regulation Best 
Interest: The Broker Dealer Standard of Conduct, 84 
Fed. Reg. 33318, at 33415-33417 (Jul. 12, 2019); 
see also SEC, Form CRS Relationship Summary; 
Amendments to Form ADV, 84 Fed. Reg. 33492 
(Jul. 12, 2019).
22    SEC, Office of the Investor Advocate, Report on 
Activities for Fiscal Year 2024 (Dec. 12, 2024), https://
www.sec.gov/files/fy24-oiad-sar-activities-report.pdf.
23 See Rule 501(a) of Regulation D [17 CFR § 
230.501(a)], or https://www.sec.gov/education/
capitalraising/building-blocks/accredited-investor. 
Individuals may also qualify under Rule 501(a)
(4), which includes any director, executive officer, 
or general partner of the issuer, or Rule 501(a)(11), 
which covers knowledgeable employees of private 
funds investing in these funds, but these additional 
categories of accredited investors were not covered in 
this research. 
24 See Katherine Carman et al., Exploring Accredited 
Investors and Private Market Securities Ownership 
(SEC, OIAD Working Paper No. 1, 2025), 
https://www.sec.gov/files/exploring-accredited-
investors-june-2025.pdf.
25    Charles Caleb Colton, LACON: OR MANY THINGS 
IN FEW WORDS; ADDRESSED TO THOSE WHO 
THINK 70, (1837).
26 See SEC, Office of the Investor Advocate, Report on 
Activities for Fiscal Year 2024 (Dec. 12, 2024), https://
www.sec.gov/files/fy24-oiad-sar-activities-report.pdf.
27 See id.
28 Exchange Act Section 4(g)(8)(B)(i), 15 U.S.C. § 78d(g)(8)
(B)(i).
29 Exchange Act Section 4(g)(8)(D), 15 U.S.C. § 78d(g)(8)
(D).
30 Exchange Act Section 4(g)(8)(D), 15 U.S.C. § 78d(g)(8)
(B), (D).
31    The 12 Primary Issue Categories can be defined as 
follows:
1. Allegations of Securities Law Violations: Investor 
alleges that an individual, firm, or entity has 
violated or is violating the U.S. securities laws. 
Where the investor makes a specific, credible 
allegation of fraud, these matters are referred to 
the Divisions of Enforcement or Examinations.
2. Atypical matters: Matters of undetermined or 
harassing nature. 
3. FINRA Complaints/Questions/Procedures: 
Questions or complaints relating to a FINRA 
investigation or arbitration, a FINRA employee, or 
about FINRA rules, policies, or procedures. 
4. Inquiries about Corporate Disclosure/Registration: 
Questions about SEC filings and other matters 
relating to corporate disclosure. 
5. Investment Products–Questions/Complaints: 
Questions or complaints about a specific type of 
investment product. 
6. Investor Account Matters: Questions or 
complaints relating to a retail investor’s personal 
investments or finances. 
7. Non-SEC/Other Matters: Questions or 
complaints about issues that do not fall within the 
SEC’s jurisdiction. 
8. Other SEC Questions/Complaints: Questions or 
complaints about the SEC, including its policies, 
procedures, rules, and employees. 
9. Other SRO Complaints/Questions/Procedures: 
Questions or complaints relating to the policies, 
procedures, or rules of an SRO other than FINRA. 
10. Potential Organized Campaign: Submission 
appears to be part of a coordinated effort by 
multiple individuals to contact the Ombuds’ Office 
about the same issue. 
11. SEC Investigations/Litigation/Enforcement 
Actions: Questions or complaints about SEC 
investigations, litigation, or other related issues, 
such as distributions. 
12. SEC/Other Impersonators: Complaints about SEC 
or SRO impersonators, and complaints involving 
fraudulent use of the SEC or SRO seal. 

20    |  OFFICE OF THE INVESTOR ADVOCATE
ERRATA SHEET
The following corrections and clarifications apply to typographical errors in certain of the Office of the 
Investor Advocate’s prior reports to Congress, as identified below.
1. The following correction applies to the Fiscal 
Year 2026 Report on Objectives (June 2025) 
regarding a typographical error in the date 
range reported in the Figure 4 label on page 
16, which reads “October 1, 2024 –  March 31, 
2024.” The correct date range is “October 1, 
2024 – March  31,  2025.”
2. The following correction applies to the Fiscal 
Year 2023 Report on Activities (December 
2023) regarding the transposition of accurately 
reported data under two different labels in 
Figures 15 and 16 on page 35. Figure 15 relates 
to the number of “Matters” received, while 
Figure 16 relates to the number of “Contacts.” 
The accurate data underlying both of those 
categories is transposed, with the number 
of matters received and corresponding chart 
misplaced under Contacts, and the number of 
contacts and corresponding chart misplaced 
under Matters. The data and corresponding 
chart relating to the number of matters 
received should be reported under “Matters,” 
while the data and corresponding chart relating 
to the number of contacts should be reported 
under “Contacts.”
3. The following correction applies to the 
Fiscal Year 2022 Report on Activities 
(December 2022) regarding the chart and 
key in Figure 13 on page 49. While the total 
number of matters discussed in the text 
on page 49 is accurate—2,780 matters—
that total did not carry through to the 
accompanying chart and key. Instead, the 
chart and key were not updated and instead 
are reproduced from the Fiscal Year 2023 
Report on Objectives (June 2022). The 
correction would update the chart and key 
in the Fiscal Year 2022 Report on Activities 
(December 2022) to match the 2,780 total 
number of matters reported in the text.



U .S . SECURITIES AND EXCHANGE COMMISSION
Washington, DC 20549
OCR text (57,107c · tika · 95% conf)
Report on 
Activities

FISCAL YEAR 2025



ABOUT THIS REPORT AND DISCLAIMER

Section 4(g)(6) of the Securities Exchange Act of 1934 (Exchange Act), 15 U.S.C. § 78d(g)(6), requires the 
Investor Advocate to file two reports per year with the Committee on Banking, Housing, and Urban Affairs 
of the Senate and the Committee on Financial Services of the House of Representatives.1 The two reports 
are the mid-year Report on Objectives covering the forthcoming Fiscal Year and the end-of-year Report on 
Activities covering the preceding Fiscal Year.

A Report on Objectives is due no later than June 30 of each year, and its purpose is to set forth the objectives 
of the Investor Advocate for the following Fiscal Year.2 A Report on Activities is due no later than December 
31 of each year.3 The Report on Activities describes the activities of the Investor Advocate during the 
immediately preceding Fiscal Year. 

Disclaimer: Pursuant to Exchange Act Section 4(g)(6)(B)(iii), 15 U.S.C. § 78d(g)(6)(B)(iii), this Report on 
Activities is provided directly to Congress without any prior review or comment from the Commission, 
any Commissioner, any other officer or employee of the Commission outside of the Office of the Investor 
Advocate or the Office of Management and Budget. This Report on Activities expresses solely the views of 
the Investor Advocate. It does not necessarily reflect the views of the Commission, the Commissioners, or 
staff of the Commission, and the Commission disclaims responsibility for this Report on Activities and all 
analyses, findings, and conclusions contained herein.



R E P O R T  O N  A C T I V I T I E S :  F I S C A L  Y E A R  2 0 2 5   |   iii

CONTENTS

MESSAGE FROM THE INVESTOR ADVOCATE.  .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   1

FISCAL YEAR 2025 SUMMARY.  .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   . 3

INVESTOR ENGAGEMENT .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .                                     4

Investor Engagement Activities.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .                                4

SEC And External Collaboration.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .                                6

FY 2025 by the Numbers.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .                                    6

Interagency Securities Council.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .                                7

ADVOCACY FOR INVESTORS.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .                                   8

Private Markets.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .                                          8

Improving Disclosures for “Main Street” Investors.  .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   . 8

Evaluating The Potential Impact of SRO Rule Proposals .  .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   . 9

RESEARCH AND INVESTOR TESTING .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .                             10

THRIVE.  .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   . 11

Accredited Investors.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .                                       11

MESSAGE FROM THE OMBUDS.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .                                  13

ENDNOTES.  .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   .   18

ERRATA SHEET.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .                                          20





R E P O R T  O N  A C T I V I T I E S :  F I S C A L  Y E A R  2 0 2 5   |   1

MESSAGE FROM THE  
INVESTOR ADVOCATE

FOR THE PAST THREE YEARS, it has been my 
privilege to serve the public and the Commission 
as the Investor Advocate. When I accepted this 
honor back in January 2023, I did so with the 
intention of serving a limited term. In January 
2026, I will leave this role and the SEC in gratitude 
for the opportunity to promote the aspirations and 
confront the challenges of investors during a period 
of time when their choices have rapidly multiplied, 
as has the complexity of the decisions they make 
when investing their capital. 

During my tenure, I have often reiterated my belief 
that the expansion of retail investment products 
and platforms in the past few years is an overall 
benefit to individual investors, while also stressing 
the urgent need for better disclosures, especially 
as the complexity of products on offer grows. 
Free and fair markets cannot flourish without 
well-informed investors who can accurately 
compare risk and opportunity and apply market 
principles to their choices. 

The impact of retail investors on the markets 
overall has grown alongside the expansion of their 
investment opportunities, making the need for 
effective retail disclosures a subject worthy of every 
market participant’s attention. At the same time, 
information many institutional investors seek and 

receive is also evolving, intensifying the focus on 
what it means to give and receive disclosures. 

Actionable and reliable disclosure is not only 
critical for informed investment decisions, it is 
necessary for sound policy development. As an 
undergraduate, I took a class with Edward Tufte 
on producing and evaluating data and statistical 
analyses for policymaking which continues to 
influence my thinking to 
this day. Sound policy 
depends on seeking 
answers to unbiased 
questions in the world 
as it is, not as we wish it 
to be.

I have endeavored to 
strengthen the investor 
research program that 
my predecessor, Rick 
Fleming, established 
when he organized the Office of the Investor 
Advocate. During my tenure, we have launched 
the production of quarterly, longitudinal data sets 
that can provide reliable, consistent, and timely 
information about retail investor behavior to the 
Commission and rule-writing teams. We have 
also maintained the ability to engage more deeply 



2  |   O F F I C E  O F  T H E  I N V E S T O R  A D V O C AT E

with investors to conduct qualitative testing and 
data collection that can inform policy making, and 
expanded our direct engagement with investors 
with different viewpoints and experiences.  

I am very grateful to Chairman Atkins and 
Commissioners Peirce, Crenshaw, and Uyeda for 
their encouragement and on-going support of 
the work of our office, especially our research. I 
hope that the data we have produced continues 
to be of service in evaluating the policy choices 
the Commission makes. I am also grateful to the 
Investor Advisory Committee, on which I have 
served as a statutory member. The volunteer 
members of the IAC give generously of their time 
and talent to provide the Commission with valuable 
insights and thoughtful recommendations.

Finally, I want to acknowledge the SEC staff, 
especially those in the Office of the Investor 
Advocate. Their dedication, expertise, and 
professionalism is a credit to the investors they 
serve, and is reflected in the legal analysis, 
engagements, and assistance they offer. In 
particular, I would like to thank Marc Sharma, 
Lisa Skrzycki, Alycia Chin, Katie Carman, Adam 
Anicich, and Andrew Sporkin, who is retiring after 
nearly four decades of service with the SEC. I have 
learned from them every day of my tenure, and I 
am proud to have been their colleague.

I am pleased to submit this Report on Activities 
for Fiscal Year 2025 on behalf of the Office of the 
Investor Advocate, and I welcome any questions 
from Members of Congress.

Respectfully Submitted,

CRISTINA BEGOÑA MARTIN FIRVIDA 
Investor Advocate 



R E P O R T  O N  A C T I V I T I E S :  F I S C A L  Y E A R  2 0 2 5   |   3

FISCAL YEAR 2025  
SUMMARY

120
ENGAGEMENT 
ACTIVITIES

2,496
INVESTOR SUBMISSIONS 
to the Ombuds

DATA COLLECTION  
ACTIVITIES
involving 
over

INDIVIDUAL INVESTOR 
CONTACTS

27,000

14
RULEMAKINGS and 
STAFF STATEMENTS 
reviewed

250+
SRO FILINGS  
reviewed



4  |   O F F I C E  O F  T H E  I N V E S T O R  A D V O C AT E

INVESTOR ENGAGEMENT

T he Office of the Investor Advocate 
(OIAD) is statutorily mandated to assist 
retail investors, identify problems that 
investors may have, analyze the potential 

impacts on investors of rules or regulations, and 
make proposals to the Commission to promote the 
interests of investors.4 

One of the primary ways in which OIAD collects 
this information and sustains a focus on investors 

is through ongoing investor engagement activities,5 
which directly support the statutory mandate and 
help amplify the voices of investors.

INVESTOR ENGAGEMENT ACTIVITIES
The Office actively seeks input from a broad range 
and variety of investors—including individual retail 
investors, smaller and regional investor groups, 
non-profits and consumer groups, academics and 

FIGURE 1. Investor Groups Consulted

OIAD 
Engagement

Retail  
Investors

Financial Industry 
Representatives

Students and Young 
Professionals

Businesses and 
Capital Seekers

Pension Plans and 
Public Retirement 

Systems

Academic and 
Advocacy Groups

Legal 
Representatives

Institutional 
Investors

Law Enforcement and 
Other Government 

Agencies



R E P O R T  O N  A C T I V I T I E S :  F I S C A L  Y E A R  2 0 2 5   |   5

researchers, public and private pension funds, and 
other small and large money managers—as well as 
regulatory and law enforcement counterparts.6

Retail investors, and their unique perspectives, 
are particularly important to OIAD. We place 
special emphasis on individuals and groups whose 
views and needs may be less frequently heard, 
including those who do not routinely travel to 
Washington, DC, to lobby government leaders, or 
who do not regularly submit comment letters to the 
Commission. Among those whom OIAD especially 
seeks to hear from are older investors, new 
investors, veterans, military, and military spouses, 
affinity-connected investors, investors from rural 
and non-metro areas, historically underserved 
and/or Native American communities, crypto and 
non-traditional finance investors, investors with 
disabilities, investors with innovative approaches 
to investing, and investors with varying levels of 
exposure to capital markets. The Office also solicits 
and encourages input from stakeholders with a 
range of epistemological perspectives and values. 

The goals for investor engagement are twofold: 

	� Understand investor experiences and 
perspectives regarding products, practices, 
regulations, rulemakings, and the markets, and 
communicate them in a decision-useful context 
for Commission leaders and staff; and 

•	 Advocate for investors’ interests in the 
regulatory and rulemaking environments 
in a manner consistent with the Office’s 
statutory mission.

This year, the Office continued to meet with 
a broad array of investors and investor 
representatives to gain from their perspectives and 
identify trends, issues, and policies that investors 
consider to be important. By leveraging virtual 
conferencing, in addition to the numerous in-person 
activities traditionally performed, OIAD welcomed 
a number of new investors and related groups to 
share their experiences with the Investor Advocate.7

One area in which OIAD further matured this year 
was to increase engagement with State and Local 
government agencies, as well as expand data-driven 
decision-support across the portfolio, which 
provided decision makers with useful and evidence-
based investor preferences, trends, and capabilities. 
OIAD has the unique ability to identify, answer, 
evaluate, and operationalize the questions of: 

	� What do we learn from investors? 
•	 What do we do with that information? 

OIAD does this, in part, by partnering with 
other Divisions and Offices to hear directly from 
investors regarding the impact that potential rules 

FIGURE 2. Types of Investor Engagement

PHASE 1
Active listening

PHASE 2
Research and  
data analysis

PHASE 3
Collaboration and 

partnerships

PHASE 4
Decision-useful 

feedback to SEC 
leaders

PHASE 5
Integration into 
SEC Policies and 

Practices



6  |   O F F I C E  O F  T H E  I N V E S T O R  A D V O C AT E

and regulations have on investors and identify 
problems that investors may have with products 
or services. The goal is to further institutionalize 
stakeholder (i.e., investor) input into all stages of 
the Commission’s operations.

SEC AND EXTERNAL COLLABORATION
OIAD further enhanced available engagement 
opportunities with other SEC Divisions and 
Offices, federal departments, state agencies, and 
law enforcement partners—so that they could hear 
directly from investors how the Commission, and 
the government, can best serve them. This included:

SEC Divisions and Offices 
The Office expanded opportunities for investors 
to communicate their perspectives directly with 
the Divisions. For example, during FY 2025, 
OIAD organized numerous investor engagement 
activities with Division and Office Directors 
and Commissioners, so they could hear investor 
commentary first-hand—including hosting an event 
titled Demystifying Capital Markets and the SEC’s 
Investor Advocacy Law School Clinic Summit. 

Federal Departments and Agencies 
In addition to the SEC, other federal departments 
and agencies are constantly working to protect 
the financial markets, products, and the American 
people. As part of the Office’s regular course of 
business, we often communicate and partner with 
federal agencies to support the larger investor 
advocacy mission, or to obtain broad investor 
and stakeholder feedback consistent with our 
statutory mission. 

State Agencies 
State Securities Regulators play a critical part in 
the regulatory and investor protection mosaic, and 
the Office continued to foster the already strong 
connections with the North American Securities 
Administrators Association (NASAA) and 
individual state regulators. 

Law Enforcement Partners 
As part of OIAD’s commitment to investors, 
understanding the evolution in investment frauds 
is of paramount concern. To enhance the Office’s 
ability to mitigate problems and promote the 
interests of investors, the Division of Enforcement 
in 2024 launched the Interagency Securities 
Council8 (ISC), with OIAD’s conceptualization 
and support. The ISC convenes recurring meetings 
between law enforcement and regulators at the 
federal, state, and local levels. Additional details 
are described in the Interagency Securities Council 
section below. 

OIAD also engaged with various local, state, 
and federal law enforcement and government 
regulatory agencies throughout the year to better 
understand the threats facing retail investors, and 
the related feedback from investors that other 
agencies are receiving. 

FY 2025 BY THE NUMBERS
OIAD hosted or substantially contributed to 
approximately 120 engagements in FY 2025, 
with one-third of those being individuals or 
organizations that had not previously met with 
the Office.9 Through these engagements, investors, 
firms, advocates, investigators, and regulators 
shared their experiences with investment products 
and providers, policy, rules, and regulation, the 
SEC and SROs, and securities fraud. 

These engagements directly informed the Investor 
Advocate’s consultations with the Chairman and 
Commissioners, Division and Office directors, 
and senior staff related to the experiences of 
everyday American investors, as well as the two 
annual reports the Office develops and submits to 
Congress, pursuant to statute.10 

The Office also presented at multiple large 
conferences, including SEC Speaks,11 the ICGN 
30th Anniversary Conference in the Americas, the 



R E P O R T  O N  A C T I V I T I E S :  F I S C A L  Y E A R  2 0 2 5   |   7

2025 CIPHER Conference, and the PwC Fraud 
Executive Roundtable. 

INTERAGENCY SECURITIES COUNCIL
The Interagency Securities Council (ISC)12 is a 
joint task force that invites federal, state, and local 
regulatory and law enforcement professionals to 
meet quarterly to discuss the latest in scams, trends, 
frauds, and mitigation strategies, and provides 
briefings on emerging and complex topics.

The ISC’s objective is to strengthen the cohesion 
between federal, state, and local agencies, enhance 
opportunities to collaborate on cases to protect 
investors, provide insight and guidance across the 
ecosystem for investigators who may not frequently 
operate in the securities space, and creates a 
forum for unified efforts in combating financial 
fraud. Chaired by the Director of the Division 

of Enforcement, OIAD’s Investor Engagement 
Manager envisioned, developed, and leads the 
SEC’s efforts on the Council.

This unique Council is limited to law enforcement 
and government regulatory agencies, and now 
includes over 2,500 representatives from more than 
250 departments and agencies,13 including federal 
financial and law enforcement agencies, state 
offices of attorneys general and state police, state 
securities regulators, and local police departments 
and sheriff’s offices. Members participate in 
discussions with experts on emerging threats, hear 
from investigators conducting and supervising 
investigations, and explore case study examples 
of agencies employing innovative approaches to 
combat financial fraud. The ISC also serves as 
an opportunity to connect and share information 
with the larger law enforcement community that 
less frequently deals with securities law violations, 
such as police/sheriff departments and tribal- and 
military-community law enforcement.

In FY 2025, the ISC conducted large meetings14 
and hosted specialized briefings with experts, 
such as a briefing on Digital Evidence Collection, 
Extraction, and Preservation with the SEC’s Office 
of Inspector General. 

The ISC was also invited by SEC’s Investor 
Advisory Committee to present on threats facing 
retail investors at the public meeting15  in March 
2025; with the presentation later being cited16 
in others’ congressional testimony, and the 
Congressional Record. 

FIGURE 3. Number of Engagements

FY 2022

72

FY 2023

142

FY 2024

112

FY 2025

120

FY 2021

88



8  |   O F F I C E  O F  T H E  I N V E S T O R  A D V O C AT E

ADVOCACY FOR INVESTORS

T his section of our annual Report on 
Activities describes a selection of our 
policy activities on behalf of investors 
for the period from October 1, 2024 

through September 30, 2025 (the Reporting Period).

PRIVATE MARKETS
During Fiscal Year 2025, the Office of the Investor 
Advocate continued to pay close attention to 
the issues surrounding the considerable growth 
of the private markets in the United States over 
the past two decades. In our prior Reports, we 
have acknowledged that the private markets have 
become an increasingly important avenue both for 
companies seeking to raise capital and for investors 
seeking investment opportunities and portfolio 
diversification. We also recognize the risks inherent 
in investing in the private markets, including 
reduced, incomplete or unreliable disclosure; 
limited liquidity; and greater risk of fraud and/or 
investment loss.

A key element of this effort has been our 
ongoing outreach to institutional and retail 
investors and other stakeholders to acquire a 
deeper understanding of the issues and different 
perspectives surrounding the private markets. 
Through this outreach, we have gained further 
insight into, and developed a greater appreciation 
of, the range of views held by investors and other 
stakeholders on topics such as expanded retail 
investor participation in the private markets, 
the inclusion of private market investments 
in retirement savings plans, the degree of 
transparency in the private markets, accredited 
investor status, and the interplay between the 
private and public markets.17

The Office has also continued to monitor pending 
legislative proposals in Congress that addressed 
various aspects of the private markets and 
evaluated the impact that these bills would have 
on investors. In addition, our Office of Investor 
Research (OIR) has engaged in ongoing research 
on topics relating to the private markets, which 
included the issuance of a working paper on 
accredited investors and private market securities 
ownership in June 2025.18

Chairman Paul Atkins has indicated that 
democratizing access to alternative assets and 
facilitating the ability of retail investors to 
participate in the private markets, consistent with 
President Trump’s Executive Order,19 is a priority 
for the Commission. Going forward, we will 
continue to focus on the issues surrounding the 
private markets and will endeavor to help ensure 
that investors’ interests remain at the forefront 
of the discussion as the Commission considers 
potential initiatives in this area.

IMPROVING DISCLOSURES FOR 
“MAIN STREET” INVESTORS
Another longstanding area of focus in the Office 
of the Investor Advocate has been the quality and 
effectiveness of disclosures provided to investors, 
particularly retail investors. Over the years, the 
Office has been supportive of the Commission’s 
efforts to assess and improve the efficacy of 
disclosures by public companies, investment 
companies, and other regulated entities. Among 
other things, we have encouraged investor testing 
as a means of improving the accessibility of 
disclosures to retail investors, as our Office of 
Investor Research has moved forward with its 



R E P O R T  O N  A C T I V I T I E S :  F I S C A L  Y E A R  2 0 2 5   |   9

innovative research efforts on investor behavior 
and decision making.

Many commentators have noted the increasing 
length and complexity of the disclosures being 
provided under the Commission’s rules and have 
raised concerns as to whether material information 
is communicated to investors under these rules in 
a more effective manner. During the Reporting 
Period, the Office sought to develop a more 
thorough understanding of how investors use 
these disclosures and to solicit a range of views on 
how to improve the effectiveness of the current 
disclosure system. Through ongoing engagements 
with retail investors and other relevant parties 
as well as our own analysis, the Office gained 
additional insight on different approaches to 
making required disclosures more user-friendly 
and comprehensible to investors, particularly retail 
investors, while also taking into account the extent 
to which this may add to the costs and burdens on 
issuers and other providers of disclosure.

According to the Commission’s most recent 
Regulatory Flexibility Act Agenda, Commission 
staff is considering rule amendments to “rationalize 
disclosure practices to facilitate material disclosure 
by companies and shareholders’ access to that 
information.” We welcome staff recommendations 
that would make disclosures more accessible to 
retail investors in a cost-effective manner, and we 
will continue to monitor developments in this area, 

including the increasing use of artificial intelligence 
in both preparing and analyzing disclosures, as we 
advocate for the disclosure needs of investors.

EVALUATING THE POTENTIAL IMPACT 
OF SRO RULE PROPOSALS
Pursuant to our statutory mandate, during 
Fiscal Year 2025, the Office of the Investor 
Advocate continued to analyze the potential 
impact on investors of proposed rules of SROs. 
Self-regulation of market intermediaries is a core 
element of the securities law framework concerning 
national exchanges, broker-dealers, and clearing 
agencies. These SROs are primarily responsible 
for establishing the standards under which their 
members conduct business and for monitoring that 
conduct; and can do so in ways that are innovative 
and fast moving. Due to potential conflicts of 
interest in their business models, however, SEC 
oversight of the SROs is an important component—
both to instill public confidence in the securities 
industry and to ultimately protect investors. During 
Fiscal Year 2025, our resources allowed our Office 
to analyze over 250 of the proposed rules of SROs. 
In Fiscal Year 2026, the Investor Advocate will 
continue to communicate with investors and their 
representatives to determine the potential impact of 
proposed rules of SROs on investors and consider 
areas in which investors could benefit from changes 
in the proposals.



10  |   O F F I C E  O F  T H E  I N V E S T O R  A D V O C AT E

RESEARCH AND 
INVESTOR TESTING

T he Exchange Act directs the Investor 
Advocate to identify problems with 
financial service providers and 
investment products and analyze 

the potential impact on investors of proposed 
regulations of the Commission and proposed rules 
of self-regulatory organizations. Pursuant to Section 
4(g)(3) of the Exchange Act, the Investor Advocate 
created OIAD’s Office of Investor Research (OIR) 
to accomplish these goals. Pursuant to Section 4(g)
(6) of the Exchange Act, OIAD summarizes OIR’s 
activities annually in its Report on Activities for 
Fiscal Year.

OIR is a multidisciplinary group that uses investor 
testing, surveys, qualitative interviews, and 
statistical modeling to study investment behavior 
and provide the Commission and the public with 
insight into how investors and other stakeholders 
interact with the investment marketplace. OIR 
provides research support to Commission offices 
and divisions seeking objective information about 
investors and responds to Congressional mandates 
for investor testing.20 Section 19(e) of the Securities 
Act, in addition to other statues, authorizes OIR to 
conduct investor testing.

OIR conducts long-term research to understand 
fundamental aspects of investor behavior and 
works with policymakers to provide an evidence 
base for policymaking. Since June 2017, OIR has 
conducted 79 survey and experimental projects, 
19 qualitative data collection projects, and several 
analyses of market data, including 8 surveys and 1 
qualitative data collection project in this fiscal year. 
OIR’s research has been published in peer-reviewed 
journals including the Journal of Economic 
Behavior & Organization and Financial Services 
Review, and cited in multiple SEC rulemakings.21 In 
Fiscal Year 2025, OIR also presented research at 
the Current Innovations in Probability-Based 
Household Internet Panel Research (CIPHER) 
conference in an effort to promote investor-related 
research within the broader scientific community.

Looking forward, OIR will continue to support 
OIAD’s statutory directive through high-quality 
research. We intend to examine investors’ decisions 
and behavior, their decision context, household 
factors, and macroeconomic trends. The rest of this 
year’s report presents a subset of results from OIR’s 
public research.

19 79qualitative quantitative



R E P O R T  O N  A C T I V I T I E S :  F I S C A L  Y E A R  2 0 2 5   |   11

THRIVE
OIR directs and maintains a nationally 
representative survey panel of U.S. retail investors 
referred to as the Thoughtful Households Relating 
InVesting Experiences (THRIVE) Panel. THRIVE 
consists of quarterly longitudinal surveys (that is, 
surveys that invite the same people over time) and 
custom testing projects that are the Commission’s 
primary research tool for understanding retail 
investors. As part of THRIVE quarterly surveys, 
7,500 people are invited to answer recurring 
questions on investment decisions and household 
events, as well as novel questions examining 
contemporaneous areas of interest.

THRIVE benefits the Commission and OIAD 
in multiple ways. Longitudinal surveys are a 
cost-effective and efficient method for evaluating 
key investor developments and identifying 
emerging investor issues, information that is 
critical to understanding investor activity, and 
promoting policy efficacy. Each quarter, OIR 
produces Perspectives on Investing in the U.S.: 
Insights from THRIVE, which contains 9 key 
measurements from each quarterly survey.

THRIVE also provides infrastructure that allows 
OIAD to quickly respond to policymakers’ needs 
by reducing the cost and time required to collect 
data. We discussed additional benefits of THRIVE 
in our 2024 Report on Activities.22 

ACCREDITED INVESTORS
Accredited investors include individuals and entities 
that meet certain criteria thought to be indicative 
of financial sophistication or the ability to bear 
financial risk, such as meeting a net worth or 
income threshold or holding certain professional 
certifications or designations. Individuals and 
entities that qualify as accredited investors may 
participate in investment opportunities such as 
private offerings conducted by issuers relying on 
Rule 506 of Regulation D.

Four ways for individuals to qualify as an 
accredited investor include (1) having a net worth 
or joint net worth with a spouse of over $1 million, 
excluding their primary residence; (2) having 
individual income that exceeds $200,000 in 
each of the prior two years and a reasonable 
expectation of that income level in the current year; 

9.7% 2.8% 2.8% 1.7%

Household 
Net Worth

Personal 
Income

Household 
Income

Specialized
Expertise

FIGURE 4. The percentage of the U.S. population that qualifies as accredited investors by criteria



12  |   O F F I C E  O F  T H E  I N V E S T O R  A D V O C AT E

(3) having joint income (with a spouse or spousal 
equivalent) that exceeds $300,000 in each of the 
prior two years and a reasonable expectation of 
that income level in the current year; or (4) holding 
certain professional certifications or other 
credentials (e.g., the Series 65 investment adviser 
representative license).23 

This year, OIAD was interested in better 
understanding the characteristics and capabilities 
of accredited investors. OIR conducted research 
in furtherance of this goal by analyzing nationally 
representative survey data from THRIVE to 
document the characteristics of accredited investors 
and non-accredited investors.24 

Based on our research, we find that 12.6% of 
individuals in the U.S. population qualify as 
accredited investors. Individuals primarily qualify 
based on their reported net worth (capturing 9.7% 
of the population), followed by personal income 
(capturing 2.8% of the population) and household 
income (capturing 2.8% of the population). 
Least common is qualifying based on specialized 
expertise (capturing 1.7% of the population). The 
majority of accredited investors (75%) satisfy only 
a single criterion, while the remaining 25% satisfy 
two or more. 4.3% of those who qualify report 
owning private market securities described in the 
question as “private funds or offerings” and further 
specifying that these types of assets typically require 
investors to meet certain criteria.



R E P O R T  O N  A C T I V I T I E S :  F I S C A L  Y E A R  2 0 2 5   |   13

MESSAGE FROM  
THE OMBUDS

There are some frauds so well conducted, that it 
would be stupidity not to be deceived by them.25 

THE OMBUDS OFFICE data reported below 
indicates that, statistically, every single day, an 
Ombuds staff member responds to an investor 
defrauded in an investment scheme. Nearly 
all of the fraud complaints reported to the 
Ombuds Office during the Reporting Period were 
made possible by digital payment services or 
cryptocurrency platforms, encrypted messaging 
systems, and the investor’s lack of information 
and experience with legitimate cryptocurrency 
investments. In this void of information, scammers 
exploit ignorance, oftentimes funneling Americans’ 
hard-earned savings out of the country and into the 
coffers of organized crime. 

Too many investors do not know legitimate 
financial professionals do not communicate 
via Instagram or WhatsApp. Investors may 
not understand why they should not fund an 
investment account by digital payments to a 
third party. Investors too often believe that an 
application available for download through their 
smartphone’s official system means it has been 
approved by the distributor and is safe. When 
sophisticated scammers impersonate legitimate 
firms, financial professionals, and government 
employees, how are Main Street investors expected 
to know the difference? 

When the staff of the Ombuds Office responds to 
defrauded investors, we have no trouble finding 
publications from the SEC and other agencies 
providing education about investing and warning 
against fraud tactics. Unfortunately, these resources 
are often identified all too late. 

During my time at the SEC providing direct 
investor assistance, I’ve 
observed my colleagues 
at the SEC and other 
agencies use every tool 
at their disposal to 
address investment fraud. 
Often jurisdictional and 
resource roadblocks 
hamper efforts to hold 
wrongdoers accountable 
or return lost funds; 
however, I am heartened 
by the successes of recent 
agency and interagency actions targeting the 
organizations allegedly responsible for much of 
the fraud reported to our office. As our previous 
Ombuds warned in last year’s Report on Activities, 
without necessary funding for law enforcement and 
regulatory agencies, we may fail to quell this rising 
tide of fraud.26 

I reiterate the prior Ombuds’ plea to Congress to 
provide the SEC, other financial regulators, and 



14  |   O F F I C E  O F  T H E  I N V E S T O R  A D V O C AT E

law enforcement agencies the necessary funds 
to address this fraudulent activity.27 Otherwise, 
agencies like the SEC are forced to divert resources 
away from our other investor protection efforts or 
risk failing to respond at all. In my observation, 
more often than not, it is the SEC frontline staff 
that shoulders this burden, drawing upon a selfless 
devotion to the agency’s mission to bridge the gap 
between what we have to work with and what 
must be done.

Our nation cannot afford to watch the savings and 
investment accounts of Americans continue to be 
raided by foreign bad actors. 

***

It has been one of the highest honors of my career 
to head the Ombuds Office during this period of 
transition and to be able to escalate the concerns 

of retail investors to the Commission’s senior 
leadership. I am humbled by the trust placed in 
me by the Investor Advocate and the Ombuds 
Office staff.

As the term of my temporary appointment to 
Acting Ombuds comes to an end in January 2026, 
I look forward to rejoining my colleagues as a 
staff attorney and supporting the goals of the next 
Investor Advocate and their appointed Ombuds. 

Finally, I extend my gratitude to the staff of the 
Ombuds Office for their steadfast commitment 
and enthusiasm in serving retail investors, and my 
colleagues in the Office of the Investor Advocate 
and across the SEC for their support of our work. 
Above all, I thank the Investor Advocate, Cristina 
Martin Firvida, for her leadership, support, and 
unwavering dedication to retail investors for the 
last three years.

Respectfully Submitted, 

LISA A. SKRZYCKI 
Acting Ombuds



R E P O R T  O N  A C T I V I T I E S :  F I S C A L  Y E A R  2 0 2 5   |   15

WHO WE ARE 
The Securities Exchange Act requires the Investor 
Advocate to appoint an Ombudsman (Ombuds) 
to act as a liaison for retail investors to relay their 
concerns and questions about the Commission 
and the self-regulatory organizations (SROs) the 
Commission oversees.28 The Ombuds staff consists 
of an experienced team of lawyers, law clerks, 
and paralegals, each with differing subject matter 
expertise, all dedicated to providing personalized, 
tailored assistance to the retail investors that 
contact the Ombuds Office for help. Through 
direct engagement with investors, relevant parties 
within the Commission, and external stakeholders 
committed to investor protection issues, the 
Ombuds Office fulfills its statutory duty to help 
retail investors resolve issues relating to the 
Commission and SROs.

Among other statutory duties, the Ombuds must 
submit biannual reports to Congress describing the 
work of the office and its effectiveness in assisting 
retail investors.29 This Ombuds’ Report provides 
a look back on the Ombuds’ activities for the 
twelve-month period of October 1, 2024, through 
September 30, 2025 (Reporting Period), and 
discusses the Ombuds’ objectives and outlook for 
Fiscal Year 2026.

WHAT WE DO 
As noted above, the Ombuds is required by 
statute to: 

	� help retail investors resolve questions and 
complaints they may have with the Commission 
or with SROs the Commission oversees; 

	� review and make recommendations regarding 
policies and procedures that encourage investors 

to present questions to the Investor Advocate 
regarding compliance with the securities laws; 

	� take steps to ensure the confidentiality of 
investor communications with our Office; and 

•	 submit biannual reports to the Investor 
Advocate that describe the activities and 
evaluate the effectiveness of the Office.30 

HOW WE HELP 
Our primary responsibility is to assist retail 
investors by resolving concerns, questions, 
and complaints about the SEC and the SROs 
subject to SEC oversight. We accomplish this in 
several ways—most commonly by conducting 
research, providing information, making referrals, 
conducting research, and collaborating with other 
divisions, offices, and SROs about complaints that 
impact investor interests. 

Many submitters who contact our Office are 
not complaining about the SEC and SROs, but 
rather seek assistance and information regarding 
fraud. When we receive credible allegations of 
securities violations, we refer this information to 
the Divisions of Examinations and Enforcement 
for potential examination, investigation, or 
action. When we receive reports of fraudsters 
impersonating the SEC or misappropriating the 
SEC’s seal, we notify staff in the Office of the 
General Counsel and Office of Inspector General. 
If an investor seeks assistance with their personal 
investments or an investment account, we refer the 
investor to the Office of Investor Education and 
Advocacy. In all cases, we endeavor to make sure 
the investor receives a clear response from the SEC 
regarding their concerns and that such concerns are 
elevated to the attention of the Investor Advocate 
and other interested parties within the Commission. 



16  |   O F F I C E  O F  T H E  I N V E S T O R  A D V O C AT E

Review

The Ombuds team reviews all incoming investor 
correspondence to determine if and how we may assist.

FIGURE 5. The Process by Which We Receive and Assist Investors with Their Requests 

Research

The Ombuds team identifies the nature of the issue, conducts 
tailored research, and engages with appropriate personnel 

within the Commission or SROs to gather relevant information.

Resolve

The Ombuds team works to resolve investor 
questions and complaints by providing 

investors with requested information and 
access to additional resources, by escalating 

certain matters through appropriate channels, when 
necessary, and by monitoring outcomes.

HOW TO CONTACT US 
Our primary means of communication with 
the public is through the Ombudsman Matter 
Management System (OMMS), an online portal 
for receiving, responding to, and managing data 
submitted to our Office. The public can also 
contact us by email, telephone, and regular mail. 

INVESTOR VOICES, BY THE NUMBERS 
The Ombuds team maintains 
records in OMMS of all submissions 
and responses handled by our 
Office. Matters are assigned a label 

or “Primary Issue Category,” reflecting the nature 
of the issues raised in the submission.31 

In tracking investor submissions by volume and by 
Primary Issue Category, OMMS may serve as an 
early warning system, flagging existing or potential 
risks for retail investors.

During the Reporting Period (October 1, 2024 –  
September 30, 2025), the Ombuds Office received 
and processed 2,496 new matters submitted by 
U.S. and foreign investors, market participants, and 
other interested members of the public. (Matters 
counted in prior reports and reopened during 
the Reporting Period are not reflected in this 
figure.) The chart below (Figure 6) illustrates the 
number of matters divided into 12 Primary Issue 
Categories, which are used to classify the nature of 
the submission.

In addition, the Ombuds team made approximately 
3,784 follow-up emails, phone calls, and other 
forms of correspondence to resolve the 2,496 
matters received and reopened matters identified in 
prior reports. This accounts for a combined total of 
6,280 contacts with or on behalf of submitters from 
October 1, 2024 to September 30, 2025. Figure 7 
details the number of follow-up contacts, separated 
by Primary Issue Category.R E P O R T  O N  A C T I V I T I E S :  F I S C A L  Y E A R  2 0 2 5   |   17

In comparison to the figures reported in FY 2024, 
the Ombuds Office has noted a slight decrease 
in the volume of new matters submitted to the 
Ombuds Office, along with a slight increase in the 
team’s efforts to resolve these matters. The total 
number of matters received in FY 2025 (2,496) 

decreased by approximately 9.96 percent from 
FY 2024 (2,772). The total number of contacts in 
FY 2025 (3,784) marked an approximate increase 
by 11.62 percent from the number of contacts in 
FY 2024 (3,390). 

FIGURE 6. Matters by Primary Issue Category, 
October 1, 2024 – September 30, 2025

Allegations of securities law violations (370)

Atypical matters (348)

Inquiries about corporate disclosure/ 
registration (53)

FINRA complaints/questions/procedures (76)

Investor account matters (439)

Investment products-questions/complaints (92)

Non-SEC/other matters (266)

SEC Investigations/litigation/enforcement  
actions (220)

SEC/other impersonators (116)

Other SEC questions/complaints (452)

Other SRO complaints (46)

Potential organized campaign (18)

Total 2,496  

FIGURE 7. Contacts by Primary Issue 
Category, October 1, 2024 – September 30, 
2025

Allegations of securities law violations (717)

Atypical matters (80)

Inquiries about corporate disclosure/ 
registration (94)

FINRA complaints/questions/procedures (141)

Investor account matters (809)

Investment products-questions/complaints (136)

Non-SEC/other matters (330)

SEC investigations/litigation/ 
enforcement actions (410)

SEC/other impersonators (294)

Other SEC questions/complaints (670)

Other SRO complaints/questions/procedures (85)

Potential Organized Campaign (18)

Total 3,784  

9%

5%

15%

14%

18%
4%

11%

18%

2%

3%

2% 1%

21%

11%

8%

19%

3%

4%

4%
9%

18%

2%

2% 0.5%



18  |   O F F I C E  O F  T H E  I N V E S T O R  A D V O C AT E

ENDNOTES

1	 Exchange Act § 4(g)(6), 15 U.S.C. § 78d(g)(6).
2	 Exchange Act § 4(g)(6)(A)(i), 15 U.S.C. § 78d(g)(6)

(A)(i).
3	 Exchange Act § 4(g)(6)(B)(i), 15 U.S.C. § 78d(g)(6)

(B)(i).
4	 See Exchange Act § 4(g)(4), 15 U.S.C. § 78d(g)

(4). Full text is available at https://www.govinfo.
gov/content/pkg/COMPS-1885/pdf/COMPS-1885.
pdf#page=57.

5	 See SEC’s Performance Goal #6: Investor Engagement 
Activities, SEC, Fiscal Year 2026 Congressional 
Budget Justification Annual Performance Plan 
Fiscal Year 2024 Annual Performance Report 
(May 30, 2025), https://www.sec.gov/files/fy-2026-
congressional-budget-justification.pdf#page=55.

6	 Investor Engagement Activities are defined in the 
SEC’s performance goals as organizing: “investor-
focused meetings, events, and activities that are 
designed primarily to engage directly with investors 
and receive feedback about policy questions, investing 
challenges, regulatory policy and rulemaking, 
investment products and services, investor issues, 
and/or potential misconduct. Investor Engagement 
Activities, defined above, include consultations 
with individual investors; small business investors; 
institutional investors; representatives from 
organizations that are comprised of, and/or represent 
the interests of, investors; other market participants 
and industry experts, and law enforcement and 
regulatory entities. This also includes a number of 
public events such as investor roundtables, public 
meetings, and academic engagement.”

7	 OIAD conducted investor engagement activities with 
approximately forty new entities/organizations in 
fiscal year 2025.

8	 See Press Release, SEC, SEC Launches Interagency 
Securities Council to Coordinate Enforcement 
Efforts Across Federal, State, and Local Agencies 
(July 19, 2024), https://www.sec.gov/newsroom/press-
releases/2024-86.

9	 Approximately 40 Investor Engagement Activities 
in FY 2025 were classified as “new engagements”—
those that included individuals or organizations that 
had not previously consulted or engaged with the 
Office of the Investor Advocate.

10	 Pursuant to 4(g)(6)(A)(i) and (B)(i) of the Exchange 
Act, the Investor Advocate is required to submit to 
the Committee on Banking, Housing, and Urban 
Affairs of the Senate and the Committee on Financial 
Services of the House of Representatives the following 
two reports each year: (1) a report on the objectives 
of the Investor Advocate for the following fiscal year, 
not later than June 30 each year; and (2) a report 
on the activities of the Investor Advocate during 
the immediately preceding fiscal year, not later than 
December 31 each year.

11	 Additional details and the full agenda for Practising 
Law Institute’s SEC Speaks event can be found 
online at https://www.pli.edu/programs/the-sec-
speaks/413804.

12	 See Press Release, SEC, SEC Launches Interagency 
Securities Council to Coordinate Enforcement 
Efforts Across Federal, State, and Local Agencies 
(July 19, 2024), https://www.sec.gov/newsroom/press-
releases/2024-86.

13	 As of September 30, 2025.
14	 The term “large meetings” generally indicates multiple 

hundreds of law enforcement and government 
regulators from one-to-two hundred departments and 
agencies all over the country.

15	 Details and the full agenda can be found at https://
www.sec.gov/about/advisory-committees/investor-
advisory-committee/iac030625-agenda.

16	 See Financial Aggression: How The Chinese 
Communist Party Exploits American Retirees and 
Undermines National Security, U.S. Senate Special 
Committee and the U.S. House Select Committee on 
the Chinese Communist Party, 119th Cong. (2025)
(statement of Christopher Iacovella, President and 
CEO, American Securities Association), https://www.
congress.gov/event/119th-congress/senate-event/
LC74495/text.

17	 This range of views is reflected in a wide array of 
recent policy recommendations from various parties 
on improving private market regulation, including 
a recommendation issued by the Investor Advisory 
Committee at its September 2025 meeting on retail 
investor access to private market assets.

18	 See Katherine Carman et al., Exploring Accredited 
Investors and Private Market Securities Ownership 
(SEC, OIAD Working Paper No. 1, 2025), 
https://www.sec.gov/files/exploring-accredited-
investors-june-2025.pdf.

https://www.govinfo.gov/content/pkg/COMPS-1885/pdf/COMPS-1885.pdf#page=57
https://www.govinfo.gov/content/pkg/COMPS-1885/pdf/COMPS-1885.pdf#page=57
https://www.govinfo.gov/content/pkg/COMPS-1885/pdf/COMPS-1885.pdf#page=57
https://www.sec.gov/files/fy-2026-congressional-budget-justification.pdf#page=55
https://www.sec.gov/files/fy-2026-congressional-budget-justification.pdf#page=55
https://www.sec.gov/newsroom/press-releases/2024-86
https://www.sec.gov/newsroom/press-releases/2024-86
https://www.pli.edu/programs/the-sec-speaks/413804
https://www.pli.edu/programs/the-sec-speaks/413804
https://www.sec.gov/newsroom/press-releases/2024-86
https://www.sec.gov/newsroom/press-releases/2024-86
https://www.sec.gov/about/advisory-committees/investor-advisory-committee/iac030625-agenda
https://www.sec.gov/about/advisory-committees/investor-advisory-committee/iac030625-agenda
https://www.sec.gov/about/advisory-committees/investor-advisory-committee/iac030625-agenda
https://www.congress.gov/event/119th-congress/senate-event/LC74495/text
https://www.congress.gov/event/119th-congress/senate-event/LC74495/text
https://www.congress.gov/event/119th-congress/senate-event/LC74495/text
https://www.sec.gov/files/exploring-accredited-investors-june-2025.pdf
https://www.sec.gov/files/exploring-accredited-investors-june-2025.pdf


R E P O R T  O N  A C T I V I T I E S :  F I S C A L  Y E A R  2 0 2 5   |   19

19	 Exec. Order No. 14330, 90 FR 38921 (Aug. 12, 
2025), https://www.whitehouse.gov/presidential-
actions/2025/08/democratizing-access-to-alternative-
assets-for-401k-investors.

20	 See, e.g., U.S. House of Representatives, Consolidated 
Appropriations Act, H.R. 2617, Pub. L. No. 117-328, 
136 Stat. 5529 (2022), https://www.congress.gov/
bill/117th-congress/house-bill/2617 (Sec. 101(b)(2)(B) 
directing the Commission to conduct investor testing 
on registered index-linked annuities).

21	 See Alycia Chin et al., How Should I Know? Lack 
of Confidence Biases Stock Market Expectations 
Toward Zero, 229 Journal of Economic Behavior 
& Organization (2025); see also Brian Scholl et al., 
Mutual Fund Knowledge Assessment for Policy and 
Decision Problems, Financial Services Review (2022); 
see also SEC, Registration for Index-Linked Annuities 
and Registered Market Value Adjustment Annuities; 
Amendments to Form N-4 for Index-Linked 
Annuities, Registered Market Value Adjustment 
Annuities, and Variable Annuities; Other Technical 
Amendments, 89 Fed. Reg. 59978 (Jul. 24, 2024); see 
also SEC, Tailored Shareholder Reports for Mutual 
Funds and Exchange-Traded Funds; Fee Information 
in Investment Company Advertisements, 87 Fed. Reg. 
72758 (Nov. 25, 2022); see also SEC, Regulation Best 
Interest: The Broker Dealer Standard of Conduct, 84 
Fed. Reg. 33318, at 33415-33417 (Jul. 12, 2019); 
see also SEC, Form CRS Relationship Summary; 
Amendments to Form ADV, 84 Fed. Reg. 33492 
(Jul. 12, 2019).

22	 SEC, Office of the Investor Advocate, Report on 
Activities for Fiscal Year 2024 (Dec. 12, 2024), https://
www.sec.gov/files/fy24-oiad-sar-activities-report.pdf.

23	 See Rule 501(a) of Regulation D [17 CFR § 
230.501(a)], or https://www.sec.gov/education/
capitalraising/building-blocks/accredited-investor. 
Individuals may also qualify under Rule 501(a)
(4), which includes any director, executive officer, 
or general partner of the issuer, or Rule 501(a)(11), 
which covers knowledgeable employees of private 
funds investing in these funds, but these additional 
categories of accredited investors were not covered in 
this research. 

24	 See Katherine Carman et al., Exploring Accredited 
Investors and Private Market Securities Ownership 
(SEC, OIAD Working Paper No. 1, 2025), 
https://www.sec.gov/files/exploring-accredited-
investors-june-2025.pdf.

25	 Charles Caleb Colton, LACON: OR MANY THINGS 
IN FEW WORDS; ADDRESSED TO THOSE WHO 
THINK 70, (1837).

26	 See SEC, Office of the Investor Advocate, Report on 
Activities for Fiscal Year 2024 (Dec. 12, 2024), https://
www.sec.gov/files/fy24-oiad-sar-activities-report.pdf.

27	 See id.
28	 Exchange Act Section 4(g)(8)(B)(i), 15 U.S.C. § 78d(g)(8)

(B)(i).
29	 Exchange Act Section 4(g)(8)(D), 15 U.S.C. § 78d(g)(8)

(D).
30	 Exchange Act Section 4(g)(8)(D), 15 U.S.C. § 78d(g)(8)

(B), (D).
31	 The 12 Primary Issue Categories can be defined as 

follows:
1.	 Allegations of Securities Law Violations: Investor 

alleges that an individual, firm, or entity has 
violated or is violating the U.S. securities laws. 
Where the investor makes a specific, credible 
allegation of fraud, these matters are referred to 
the Divisions of Enforcement or Examinations.

2.	 Atypical matters: Matters of undetermined or 
harassing nature. 

3.	 FINRA Complaints/Questions/Procedures: 
Questions or complaints relating to a FINRA 
investigation or arbitration, a FINRA employee, or 
about FINRA rules, policies, or procedures. 

4.	 Inquiries about Corporate Disclosure/Registration: 
Questions about SEC filings and other matters 
relating to corporate disclosure. 

5.	 Investment Products–Questions/Complaints: 
Questions or complaints about a specific type of 
investment product. 

6.	 Investor Account Matters: Questions or 
complaints relating to a retail investor’s personal 
investments or finances. 

7.	 Non-SEC/Other Matters: Questions or 
complaints about issues that do not fall within the 
SEC’s jurisdiction. 

8.	 Other SEC Questions/Complaints: Questions or 
complaints about the SEC, including its policies, 
procedures, rules, and employees. 

9.	 Other SRO Complaints/Questions/Procedures: 
Questions or complaints relating to the policies, 
procedures, or rules of an SRO other than FINRA. 

10.	Potential Organized Campaign: Submission 
appears to be part of a coordinated effort by 
multiple individuals to contact the Ombuds’ Office 
about the same issue. 

11.	SEC Investigations/Litigation/Enforcement 
Actions: Questions or complaints about SEC 
investigations, litigation, or other related issues, 
such as distributions. 

12.	SEC/Other Impersonators: Complaints about SEC 
or SRO impersonators, and complaints involving 
fraudulent use of the SEC or SRO seal. 

https://www.whitehouse.gov/presidential-actions/2025/08/democratizing-access-to-alternative-assets-f
https://www.whitehouse.gov/presidential-actions/2025/08/democratizing-access-to-alternative-assets-f
https://www.whitehouse.gov/presidential-actions/2025/08/democratizing-access-to-alternative-assets-f
https://www.congress.gov/bill/117th-congress/house-bill/2617
https://www.congress.gov/bill/117th-congress/house-bill/2617
https://www.sec.gov/files/fy24-oiad-sar-activities-report.pdf
https://www.sec.gov/files/fy24-oiad-sar-activities-report.pdf
https://www.sec.gov/education/capitalraising/building-blocks/accredited-investor
https://www.sec.gov/education/capitalraising/building-blocks/accredited-investor
https://www.sec.gov/files/exploring-accredited-investors-june-2025.pdf
https://www.sec.gov/files/fy24-oiad-sar-activities-report.pdf
https://www.sec.gov/files/fy24-oiad-sar-activities-report.pdf


20  |   O F F I C E  O F  T H E  I N V E S T O R  A D V O C AT E

ERRATA SHEET

The following corrections and clarifications apply to typographical errors in certain of the Office of the 
Investor Advocate’s prior reports to Congress, as identified below.

1.	 The following correction applies to the Fiscal 
Year 2026 Report on Objectives (June 2025) 
regarding a typographical error in the date 
range reported in the Figure 4 label on page 
16, which reads “October 1, 2024 – March 31, 
2024.” The correct date range is “October 1, 
2024 – March 31, 2025.”

2.	 The following correction applies to the Fiscal 
Year 2023 Report on Activities (December 
2023) regarding the transposition of accurately 
reported data under two different labels in 
Figures 15 and 16 on page 35. Figure 15 relates 
to the number of “Matters” received, while 
Figure 16 relates to the number of “Contacts.” 
The accurate data underlying both of those 
categories is transposed, with the number 
of matters received and corresponding chart 
misplaced under Contacts, and the number of 
contacts and corresponding chart misplaced 
under Matters. The data and corresponding 

chart relating to the number of matters 
received should be reported under “Matters,” 
while the data and corresponding chart relating 
to the number of contacts should be reported 
under “Contacts.”

3.	 The following correction applies to the 
Fiscal Year 2022 Report on Activities 
(December 2022) regarding the chart and 
key in Figure 13 on page 49. While the total 
number of matters discussed in the text 
on page 49 is accurate—2,780 matters—
that total did not carry through to the 
accompanying chart and key. Instead, the 
chart and key were not updated and instead 
are reproduced from the Fiscal Year 2023 
Report on Objectives (June 2022). The 
correction would update the chart and key 
in the Fiscal Year 2022 Report on Activities 
(December 2022) to match the 2,780 total 
number of matters reported in the text.





U.S. SECURITIES AND EXCHANGE COMMISSION
Washington, DC 20549