Spotlight: 2026 SEC Exam Priorities

The SEC's Division of Examinations has released its Fiscal Year 2026 priorities and the message under new Chairman Paul Atkins is clear: exams should not be a "gotcha" exercise, but firms whose compliance programs exist only on paper will have nowhere to hide. With fewer resources, expect fewer but deeper, more targeted examinations. 

Here’s a breakdown the SEC’s 2026 Examination Priorities: 

Investment Products & Recommendations 

• Conflicts of interest — disclosure alone is no longer sufficient; firms must demonstrate active mitigation through supervision, documentation, and decision-making controls. 

• Complex and illiquid products — private credit, leveraged/inverse ETFs, annuities, and structured products face heightened scrutiny around suitability and whether disclosures match actual portfolio practices. 

Technology & Operational Risk 

• Cybersecurity — elevated to a firmwide governance issue, with Regulation S-P amendments bringing incident response and customer notification programs into focus. 

• AI and automated tools — examiners want to see meaningful oversight of algorithms and confirmation that marketing claims about AI capabilities hold up. 

Compliance Programs & Who's Being Examined 

• Compliance program effectiveness — annual reviews must be substantive and risk-based, not procedural; examiners will assess whether policies are genuinely tailored to a firm's actual business model and enforced in practice. 

• Firms in transition — those that have changed business models, begun advising new asset classes, launched private funds, or completed mergers face particular scrutiny. 

• New and never-examined firms — expect rigorous, comprehensive first exams. 

• Private fund advisers — no longer a standalone section for the first time since 2021, with topics folded into broader thematic categories. 

• Crypto assets — dropped as a standalone priority for the first time since 2018, reflecting a recalibration under the new administration. 

  
  

For the full breakdown, read WebCE’s complete SEC Examination Priorities 2026: Key Changes & Preparation Guide.