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SEC Sets FY2026 Exam Priorities, Elevates Cyber and AI Risks, Starts SBSEF Exams

The release underscores a cooperative, remediation-first exam posture.

Overview

  • Published on November 17, 2025, the Division of Examinations outlined FY2026 priorities with a non-punitive tone, dropping a standalone crypto section in favor of folding those risks into existing program areas.
  • Investment advisers face heightened reviews of fiduciary duty, conflicts, best execution, and recommendations involving complex or higher-cost products, with attention to retail clients and newly registered or restructured firms.
  • Broker-dealer exams emphasize financial responsibility rules, best execution and order handling, updated trading-practice reviews, Regulation Best Interest for complex products, and enhanced disclosure expectations such as Rule 605 information.
  • Information security remains a core focus as exams assess readiness for amended Regulation S‑P incident-response obligations, compliance with Regulation S‑ID identity‑theft programs, and controls for AI-driven threats and operational resiliency.
  • The SEC will begin examining registered SBSEFs and continue scrutinizing SBSDs’ SBSR reporting, capital, margin, and segregation, with time-limited SBSR relief extended to 2029 allowing CFTC‑aligned reporting during the interim.