A working list of the topics in the SEC Division of Examinations' fiscal year 2027 priorities, kept so this site's own record-keeping, information security and anti-money-laundering practices can be checked against them. This site is not affiliated with, endorsed by or reporting for the SEC.
Source: SEC Division of Examinations, FY 2027 Examination Priorities (PDF, 0.95 MB, SHA-256 83dc9c3c3aa5fa02afa325587f1d3c25dad333881b19c0f3f7ea314d8cfa3748) · press release
This statement represents the views of the staff of the Division of Examinations. It is not a rule, regulation, or statement of the U.S. Securities and Exchange Commission (SEC or Commission). The Commission has neither approved nor disapproved its content. This statement, like all staff statements, has no legal force or effect: it does not alter or amend applicable law, and it creates no new or additional obligations for any person.
| Item | Topic | Page | Summary | Status |
|---|---|---|---|---|
| 0 | Message from the Leadership Team (context) | 1 | Context, not a priority: EXAMS aims to be more accessible and integrated (new SEC Exam Handbook, CFTC and NFA MOUs, FINRA coordination) and is studying how registrants' super intelligence (SI) use affects outcomes and compliance. | open |
| I.A | Investment Advisers: Fiduciary Standards of Conduct | 5 | Advisers' fiduciary duties, especially for retail, older and retirement investors: full and fair disclosure, due diligence, valuation, economic conflicts (fee rebates, cash management, quid pro quo), how advice is formed, illiquid or complex products, private fund disclosures, third-party access to client accounts, and reliance on proxy advisers. | open |
| I.B | Investment Advisers: Compliance Programs | 6 | Core compliance program components (marketing, valuation, trading, portfolio management, disclosure and filings, custody) and the annual review; conflict policies, fee-related disclosures; advisers that changed business models, grew by merger or acquisition, or run dispersed branches; activist advisers' Schedule 13D/13G and Form 13F, 13H, 3, 4, 5 and N-PX filings. | open |
| I.C | Investment Advisers: Never-Examined and Recently Registered Advisers | 7 | Exams of advisers never examined, with emphasis on recently registered ones: compliance with regulatory requirements and processes for identifying, addressing and disclosing risks and conflicts of interest. | open |
| II | Investment Companies | 7 | Registered investment companies (mutual funds, ETFs): fund fees and expenses including waivers and reimbursements; portfolio management versus stated strategies, filings and marketing; complex or illiquid holdings such as private credit; leveraged funds (BDCs, inverse and leveraged ETFs); exemptive-order compliance; never-examined RICs. | open |
| III.A | Broker-Dealers: Financial Responsibility Rules | 7 | Net Capital Rule and Customer Protection Rule, including amendments on daily customer reserve computations and U.S. Treasury clearing; credit, market and liquidity risk controls for stress events; prime brokerage concentration, liquidity and counterparty credit risk. | open |
| III.B | Broker-Dealers: Trading-Related Practices and Services | 7 | Equity and fixed-income trading: extended trading hours (operations, liquidity providers on and off exchange, market and credit risk policies), order routing and best execution, pricing of illiquid instruments such as private credit and private equity, and priority of orders in municipal securities. | open |
| III.C | Broker-Dealers: Retail Sales Practice, Including Regulation Best Interest | 8 | Reg BI recommendations (including account and rollover), conflict mitigation, reasonably available alternatives, Disclosure and Care Obligations; complex or high-risk products; recommendations to older and vulnerable investors; dual registrants; account selection and allocation; Form CRS content and disciplinary history; payments to unregistered finders. | open |
| III.D | Broker-Dealers: Anti-Money Laundering (AML) | 8 | Whether AML programs are tailored and updated (omnibus accounts for foreign financial institutions, rapid growth), independently tested, address foreign-company trading and pump-and-dump or ramp-and-dump schemes, include ongoing customer due diligence and SAR filing, special due diligence for foreign correspondent accounts, and OFAC sanctions compliance. | open |
| III.E | Broker-Dealers: Supervision | 9 | Whether broker-dealers, funding portals, municipal advisors and security-based swap dealers keep supervisory systems, written policies and internal controls reasonably designed for compliance, including for new business lines and products, with qualified supervisors who have authority. | open |
| IV.A | Self-Regulatory Organizations: National Securities Exchanges | 9 | Whether national securities exchanges meet their obligations to enforce SRO rules and the federal securities laws, focusing on regulatory programs and governance. | open |
| IV.B | Self-Regulatory Organizations: FINRA | 9 | Risk-based oversight exams of FINRA's major regulatory programs and of FINRA's exams of certain broker-dealers, funding portals and municipal advisors, with detailed recommendations to improve FINRA's programs and risk assessment. | open |
| IV.C | Self-Regulatory Organizations: MSRB | 10 | Exams of registered firms for compliance with MSRB rules, with FINRA and the banking regulators, and a risk assessment process like FINRA's to pick areas to examine at the MSRB. | open |
| IV.D | Self-Regulatory Organizations: PCAOB | 10 | Inspections of the PCAOB, using a risk assessment process like the one used for FINRA and the MSRB to identify areas to inspect. | open |
| V | Clearing Agencies | 10 | Annual exams of systemically important clearing agencies (Dodd-Frank Title VIII): default management, recovery and wind-down, securities lending, operations, tokenization; Covered Clearing Agency standards and corrective action on prior findings; new rules on Treasury clearing, governance, wind-down plans and straight-through processing. | open |
| VI.A | Other Market Participants: Municipal Advisors | 11 | Fiduciary duty to municipal entity clients (pricing and method of sale, competitive versus negotiated sale), MSRB Rule G-42 conflicts disclosure and documentation, required SEC filings, qualification, registration, recordkeeping and supervision. | open |
| VI.B | Other Market Participants: Transfer Agents | 11 | Use of emerging technology for transfer agent functions; processing of items and transfers, recordkeeping and retention, safeguarding funds and securities, SEC filings; Regulation S-P amendments (Safeguards Rule, Disposal Rule, incident response programs). | open |
| VI.C | Other Market Participants: Funding Portals | 11 | Arrangements with qualified third parties to hold and transmit investor funds, making and preserving required records, and possibly Regulation S-P amendment compliance (Safeguards Rule, Disposal Rule, incident response). | open |
| VI.D | Other Market Participants: Security-Based Swap Dealers (SBSDs) | 11 | Accurate Regulation SBSR reporting of security-based swaps to data repositories, remediation of issues in annual Chief Compliance Officer reports, and never-examined SBSDs. | open |
| VI.E | Other Market Participants: Security-Based Swap Execution Facilities (SBSEFs) | 11 | Registered SBSEFs' rules and policies on trade monitoring, trade processing and participation, and their programs of risk analysis and oversight to minimize operational risk. | open |
| VII.A.1 | Risk Areas: Information Security and Operational Resiliency: Cybersecurity | 12 | Policies on governance, data loss prevention, access controls, account management, and response and recovery for cyber incidents including ransomware; risks from third-party service providers and shared technologies. | open |
| VII.A.2 | Risk Areas: Information Security and Operational Resiliency: Emerging Financial Technology | 12 | Preparation for SI-driven cyberattacks (SI-generated phishing, deepfake voice and video); policies for monitoring SI in fraud detection, back office, AML, Reg BI and trading; automated advice tools and algorithms: fair representations, controls matching disclosures, advice consistent with investor profiles. | open |
| VII.A.3 | Risk Areas: Information Security and Operational Resiliency: Regulation S-ID and Regulation S-P | 12 | Reg S-P safeguards for customer information, response programs for unauthorized access including customer notification and service provider oversight; Reg S-ID red flags for identity theft, account takeovers and fraudulent transfers, and program updates for SI and stolen credentials. | open |
| VII.B | Risk Areas: Regulation Systems Compliance and Integrity (SCI) | 13 | Emerging trends under Reg SCI (SI, tokenization of securities, extended trading hours, quantum computing) and SCI entities' reliance on cloud and third-party vendors, including how they manage vendor risk and identify SCI or indirect SCI systems. | open |
p. = page number printed in the PDF; PDF page = printed + 4. "open" means not yet reviewed against this site's practices.