Overview
- The Division will prioritize recently registered or never‑examined advisers, with added attention to dual registrants, firms using third‑party access to client assets or data, and post‑merger integrations.
- Reviews will test adherence to fiduciary duties, assessing how advisers manage conflicts, consider costs and product characteristics, and seek best execution for clients, including older and retirement‑focused investors.
- Examiners will evaluate the effectiveness of compliance programs across marketing, disclosures and fee conflicts, valuation, trading, portfolio management, and custody.
- Marketing rule compliance remains a focus, including substantiation of material claims, use of hypothetical performance, testimonials or endorsements, third‑party ratings, and related books‑and‑records.
- Cybersecurity and operational resiliency will be probed, including AI‑related risks and compliance with Regulations S‑ID and S‑P, with testing planned after the December 3, 2025 and June 3, 2026 S‑P deadlines.