06/18/2026
Jacko Law Group, PC Regulatory Tip of the Week
by Michelle L. Jacko
Notice: Amended Qualified Client Thresholds Take Effect June 29, 2026
Advisers that assess performance fees should be on notice that effective June 29, 2026, the Qualified Client Threshold, which allows advisers to charge performance-based fees to clients, will increase from $1.1 million to $1.4 million for the AUM test, and from $2.2 million to $2.7 million for the net worth test (excluding client’s primary residence).
This is especially relevant for smaller to mid-sized RIAs whose clients usually sit close to the threshold.
The increase will not affect existing performance fee arrangements, however, any new contracts on or after June 29, 2026, must adhere to the new threshold. (https://na2.hubs.ly/H06c1BJ0)
To comply with SEC requirements, we recommend RIAs do the following:
· Update Form ADV disclosures and other relevant documents, including client questionnaires, intake forms, and any subscription documents to reflect these new requirements.
· Provide training to advisory personnel to ensure they are aware of the new requirements
· Ensure that client onboarding procedures are updated to account for the new thresholds.
· Verify that net worth calculations exclude the primary residence.
For more information on addressing the increased Qualified Client Threshold, please contact us at 619.298.2880 or email [email protected]
Disclaimer: General information only. Not legal advice. No attorney-client relationship is created.