The U.S. Securities and Exchange Commission (SEC) has published its Division of Examinations’ fiscal 2027 priorities, emphasizing investment advice and conflicts of interest, complex and illiquid products, and technology and market infrastructure risks. The priorities guide a risk-based examination program covering more than 34,000 registrants. They are not exhaustive, and firms are expected to maintain compliance programs tailored to their businesses as examination focus areas evolve with market conditions. For investment advisers, reviews will prioritize economic conflicts, including fees and compensation arrangements, and whether recommendations reflect clients’ objectives, risk tolerance and liquidity needs. Private fund examinations will scrutinize risk disclosures, borrowing, affiliated service providers and fee calculations. Registered fund reviews will address valuation, redemptions and disclosures associated with private credit and other illiquid investments. Broker-dealer examinations will assess Regulation Best Interest compliance, particularly for complex products and recommendations to older or vulnerable investors. Financial responsibility, supervision and anti-money laundering controls remain priorities, including risks from foreign omnibus accounts and international market manipulation. Across firms, examiners will assess cybersecurity, service provider oversight and customer information safeguards, including incident response and notification procedures under amended Regulation S-P. Reviews of super intelligence will examine firms’ monitoring controls, automated recommendations and preparation for cyberattacks using the technology. Market infrastructure examinations will address tokenization, extended trading hours and expanded Treasury clearing, including related customer reserve requirements and clearing agency controls. That clearing focus comes as previously established compliance deadlines approach on Dec. 31, 2026, for eligible Treasury cash transactions and June 30, 2027, for eligible repo transactions. Separately, the division is working to improve registrants’ access to examination observations and strengthen coordination with SEC policymaking offices and other regulators.

Related updates