On November 17, 2025, the staff of the SEC’s Division of Examinations released its examination priorities for fiscal year 2026. The release highlights areas of focus for various regulated entities, including, among others, investment companies, investment advisers and broker-dealers.
Investment Companies
Examinations of investment companies will continue to focus on compliance programs, disclosures, filings and governance practices. In particular, the staff noted a focus on fund fees and expenses and related fee waivers and expense reimbursements. The staff also noted a focus on portfolio management practices and disclosures for consistency regarding investment strategies or approaches and for consistency with the amended Names Rule (Rule 35d-1 under the Investment Company Act of 1940) following the compliance date. The staff also highlighted additional areas of interest, including funds with complex strategies or significant less-liquid or illiquid holdings (e.g., closed-end funds) and related issues regarding valuation and conflicts of interest, funds with novel strategies or investments (e.g., funds with leverage), and operational and compliance issues arising in connection with fund mergers.
Investment Advisers
Examinations of investment advisers will continue to focus on advisers’ adherence to their fiduciary duties of care and loyalty. The staff highlighted a focus on investment products with alternative investments (e.g., private credit and private funds), investment products with complex investments (e.g., ETFs with less liquid strategies, option-based ETFs, and leveraged and/or inverse ETFs) and higher cost investment products. The staff will also focus on investment recommendations for consistency with product disclosures and client profiles, emphasizing recommendations to retirement savers and older investors, advisers managing private funds and products sensitive to market volatility. In addition, the staff stated that it remains focused on advisers’ compliance programs, including the core areas of marketing, valuation, trading, portfolio management, disclosure and filings, and custody. Additional areas identified include implementation and enforcement of policies and procedures and whether disclosures address fee-related conflicts.
Broker-Dealers
The staff stated that it will continue to examine broker-dealer compliance with financial responsibilities rules, including the net capital rule and the customer protection rule, and will review firms’ operational resilience programs and risk management controls. The staff also highlighted a continued focus on broker-dealer equity and fixed income trading practices, including best execution, pricing and valuation of illiquid investments, and disclosures regarding order routing and order execution information. Additionally, the staff will continue to examine sales practices, including Regulation Best Interest compliance. In this regard, the staff identified several areas of particular interest including, among others, complex or tax advantaged products, ETFs with illiquid investments such as private equity or private credit, municipal securities, private placements, structured products, and products representing growth areas for retail investment.
Risk Areas Impacting Various Market Participants
With respect to various market participants, the SEC staff highlighted examination priorities regarding information security and operational resiliency, including cybersecurity and compliance with Regulations S‑ID and S-P, noting the recent amendments to Regulation S-P. The staff remains focused on the use of artificial intelligence and other emerging financial technologies and related disclosures and controls. The Regulation Systems Compliance and Integrity (SCI) framework for oversight of the U.S. securities markets’ technology infrastructure, as well as anti-money laundering, also remain examination priorities.
The Division of Examinations’ 2026 examination priorities are available here and a related press release is available here.
