The SEC has announced its 2026 examination priorities, highlighting areas of heightened regulatory focus. Firms should review these priorities carefully and assess their compliance programs to identify where additional strengthening may be required.
“Examinations are an important component to accomplishing the agency’s mission, but they should not be a ‘gotcha’ exercise,” said SEC Chairman Paul S. Atkins. “Today’s release of examination priorities should enable firms to prepare to have a constructive dialogue with SEC examiners and provide transparency into the priorities of the agency’s most public-facing division.”
Key Highlights from the SEC’s 2026 Priorities
- Fiduciary Duty & Conflicts of Interest: Examiners will assess whether advisers provide impartial advice and fully disclose financial conflicts that could influence client recommendations.
- Quality of Investment Advice: Reviews will evaluate whether advisers appropriately consider costs, risks, liquidity, and product characteristics when formulating investment advice.
- Suitability for Clients: The Division will check that recommendations fit clients’ objectives and risk tolerance, with heightened scrutiny for older investors, retirement savers, and in respect of private fund advisers with multiple clients.
- High-Risk Products & Strategies: Examiners will focus on alternative, complex, volatile, or higher-cost products to ensure advisers properly analyze and disclose their risks.
- Higher-Risk Adviser Practices: Oversight will intensify for dually registered advisers, firms using third-parties to access clients’ accounts, and advisers undergoing mergers that may introduce new conflicts or operational weaknesses.
- Compliance Programs & Regulation S-P: The Division will evaluate whether advisers’ compliance programs are effective, implemented, and updated—including adherence to the new Regulation S-P requirements for safeguarding customer information and incident response.
Click here for the full press release.
The SEC’s priorities are not exhaustive; firms should continue monitoring evolving risks across their operations. Should you require assistance in reviewing these priorities, enhancing compliance frameworks, or preparing for SEC examinations please reach out to discuss our services and how we can help.
