SEC 2026 Examination Priorities: What’s New, What’s Changing, and What It Signals

The Division’s release of the 2026 Examination Priorities less than a week after the government reopened underscores the SEC’s readiness to move quickly into the new fiscal year. While the priorities do not introduce major changes from last year, there are some notable differences.

Notable highlights in the 2026 Examination Priorities include:

• Private Funds
  Focus on advisers with separately managed accounts, newly registered funds, or firms advising private funds for the first time.
• RegTech & Third-Party Access Tools
  Heightened scrutiny of third-party platforms that allow adviser access to client accounts (e.g., 401(k) credential-sharing tools) where controls may be insufficient to protect client data or assets.
• Adviser M&A Activity
  Review of mergers and acquisitions that create operational and compliance risks; examiners will look for adherence to advisory agreements and transparency in client disclosures.
• AI & Cybersecurity
  Emphasis on staff training, strengthened security controls, and the effective use of threat-intelligence information in day-to-day operations.
• Regulatory Program Compliance (Reg S-P & Reg S-ID)
  Assessment of whether privacy and identity-theft programs are reasonably designed to detect red flags and meet required training obligations.
• Digital Assets
  Notable absence of previously highlighted crypto-asset areas, reflecting a shift in regulatory posture and ongoing efforts to build a more structured oversight framework.