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FISCAL YEAR 2025

Report on

Activities

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.

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

iii

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

REPORT ON ACTIVITIES: FISCAL YEAR 2025

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

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

FISCAL YEAR 2025

SUMMARY

120

ENGAGEMENT

ACTIVITIES

2,496

INVESTOR SUBMISSIONS

to the Ombuds

RULEMAKINGS and

STAFF STATEMENTS

reviewed

DATA COLLECTION

ACTIVITIES

involving

over

27,000

INDIVIDUAL INVESTOR

CONTACTS

250+

SRO FILINGS

reviewed

REPORT ON ACTIVITIES: FISCAL YEAR 2025

INVESTOR ENGAGEMENT

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

Retail

Investors

Financial Industry

Representatives

Legal

Representatives

Students and Young

Professionals

OIAD

Engagement

Academic and

Advocacy Groups

Businesses and

Capital Seekers

Institutional

Investors

Pension Plans and

Public Retirement

Systems

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 and

Other Government

Agencies

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 evidencebased 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

PHASE 2

PHASE 3

PHASE 4

PHASE 5

Active listening

Research and

data analysis

Collaboration and

partnerships

Decision-useful

feedback to SEC

leaders

Integration into

SEC Policies and

Practices

REPORT ON ACTIVITIES: FISCAL YEAR 2025

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.

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 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

of Enforcement, OIAD’s Investor Engagement

Manager envisioned, developed, and leads the

SEC’s efforts on the Council.

FIGURE 3. Number of Engagements

142

112

120

FY 2021 FY 2022 FY 2023 FY 2024 FY 2025

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

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.

REPORT ON ACTIVITIES: FISCAL YEAR 2025

ADVOCACY FOR INVESTORS

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

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

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

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.

REPORT ON ACTIVITIES: FISCAL YEAR 2025

RESEARCH AND

INVESTOR TESTING

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.

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

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.

qualitative

quantitative

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.

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;

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

9.7%

2.8%

1.7%

Household

Net Worth

Personal

Income

Household

Income

Specialized

Expertise

REPORT ON ACTIVITIES: FISCAL YEAR 2025

(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

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

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.

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

REPORT ON ACTIVITIES: FISCAL YEAR 2025

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.

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.

Our nation cannot afford to watch the savings and

investment accounts of Americans continue to be

raided by foreign bad actors.

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.

***

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

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.

Respectfully Submitted,

LISA A. SKRZYCKI

Acting Ombuds

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

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.

REPORT ON ACTIVITIES: FISCAL YEAR 2025

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

Review

The Ombuds team reviews all incoming investor

correspondence to determine if and how we may assist.

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

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.

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

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.

FIGURE 6. Matters by Primary Issue Category,

October 1, 2024–September 30, 2025

FIGURE 7. Contacts by Primary Issue

Category, October 1, 2024–September 30,

2025

0.5%

15%

18%

19%

18%

14%

11%

21%

18%

Allegations of securities law violations (370)

Atypical matters (348)

Allegations of securities law violations (717)

Inquiries about corporate disclosure/

registration (53)

Atypical matters (80)

FINRA complaints/questions/procedures (76)

Inquiries about corporate disclosure/

registration (94)

Investor account matters (439)

FINRA complaints/questions/procedures (141)

Investment products-questions/complaints (92)

Investor account matters (809)

Non-SEC/other matters (266)

Investment products-questions/complaints (136)

SEC Investigations/litigation/enforcement

actions (220)

Non-SEC/other matters (330)

SEC/other impersonators (116)

SEC investigations/litigation/

enforcement actions (410)