Overview
- Published on Nov. 17, 2025, the priorities apply across advisers, broker‑dealers, investment companies, self‑regulatory organizations, clearing agencies and municipal advisors.
- Examiners will assess advice and disclosures for fiduciary compliance, emphasizing conflicts, costs, best execution, complex and alternative products, and recommendations to older investors and private funds.
- Reviews will test the effectiveness of compliance programs in marketing, valuation, trading, portfolio management, custody, and required filings including Schedules 13D/13G, Form 13F, and Forms 3–5 and N‑PX.
- Information‑security oversight covers identity‑theft programs under Regulation S‑ID and new incident‑response obligations under amended Regulation S‑P, with compliance dates of Dec. 3, 2025 for larger advisers and June 3, 2026 for smaller firms.
- Targeted exams will scrutinize dual registrants, third‑party account access and post‑merger integrations, prioritize never‑examined or recently registered firms, and review representations and controls around AI and automated tools.