SEC Highlights 2026 Exam Priorities

In an annual report, the SEC Division of Examinations identified priority areas for examination and highlighted key risks for investors and registrants in 2026. 

The Division focused on the following priorities:

• Investment Advisers. For investment advisers, the Division said it will continue to review their adherence to fiduciary duties, with a focus on conflicts of interest, best execution and recommendations involving complex products, including those made to older investors and retirement savers. The Division will also assess the effectiveness of advisers’ compliance programs across areas such as marketing, valuation and custody.  The Division said it will also prioritize examinations of newly registered and other never-examined firms.
• Investment Companies.  For registered investment companies, the Division said examinations will address fees and expenses, governance, alignment between stated strategies and actual portfolio management and compliance with the amended "Names Rule." 
• Broker-Dealers.  For broker-dealers, the Division said examinations will focus on compliance with Regulation Best Interest, particularly recommendations on complex products, account types and rollovers, as well as firms’ conflict-management practices. The Division said it will also review compliance with financial responsibility rules—including net capital and customer protection requirements—alongside liquidity and credit risk management. Additional reviews will cover trading practices, best execution procedures, order routing disclosures, and Regulation SHO compliance.
• Self-Regulatory Organizations. The Division said it will continue to review governance, surveillance and enforcement practices of national securities exchanges, and it will conduct risk-based oversight of FINRA and the MSRB.
• Clearing Agencies. The Division said examinations will focus on risk-management frameworks, including liquidity, margin methodologies, model validation and oversight of third-party service providers. 

The Division also said it will conduct examinations on other market participants, including municipal advisors, transfer agents, funding portals and security-based swap dealers, with emphasis on the following areas:

• Information Security and Operational Resiliency. The Division said it will closely scrutinize registrants’ cybersecurity practices, including data-loss prevention, governance, access controls, vendor oversight and incident response programs. The Division said it will also evaluate compliance with Regulation S-P and Regulation S-ID, including preparations for the newly adopted amendments to Regulation S-P.
• Emerging Financial Technologies. The Division said it will continue to assess firms’ use of automated investment tools, AI and trading algorithms, including whether disclosures about such technologies are fair and accurate and whether their use leads to advice aligned with investors’ profiles. The Division said it will review controls over third-party AI systems and firms’ integration of regulatory technology.
• Anti-Money Laundering. The Division said it will examine whether firms have appropriately tailored their AML programs to business-specific risks, including independent testing, customer identification programs and Suspicious Activity Report filings. The Division will also evaluate compliance with U.S. Treasury sanctions.
• Regulation Systems Compliance and Integrity ("Regulation SCI"). The Division said it will review SCI entities to ensure they maintain systems designed for operational integrity and resiliency, with a focus on incident response, cybersecurity defenses and oversight of third-party vendors.