The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu The leading online blog in the fields of corporate governance and financial regulation. Mon, 13 Apr 2026 14:14:10 +0000 en-US hourly 1 https://wordpress.org/?v=6.5.8 https://corpgov.law.harvard.edu/wp-content/uploads/2024/02/cropped-photography-4-e1706898544564-1-32x32.png 2026 SEC Exam Priorities and Implications for Investment Advisers and Investment Funds – The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu 32 32 2026 SEC Exam Priorities and Implications for Investment Advisers and Investment Funds https://corpgov.law.harvard.edu/2025/12/14/2026-sec-exam-priorities-and-implications-for-investment-advisers-and-investment-funds/?utm_source=rss&utm_medium=rss&utm_campaign=2026-sec-exam-priorities-and-implications-for-investment-advisers-and-investment-funds https://corpgov.law.harvard.edu/2025/12/14/2026-sec-exam-priorities-and-implications-for-investment-advisers-and-investment-funds/#respond Sun, 14 Dec 2025 12:30:04 +0000 https://corpgov.law.harvard.edu/?p=178129?d=20251212144515EST Posted by Timothy Clark, Melissa Hodgman, and David Nicolardi, Freshfields Bruckhaus Deringer LLP, on Sunday, December 14, 2025
Editor's Note:

Timothy Clark is the Global Co-Head of Private Funds and Secondaries, Melissa Hodgman is a Partner, and David Nicolardi is Counsel at Freshfields Bruckhaus Deringer LLP. This post is based on a Freshfields memorandum by Mr. Clark, Ms. Hodgman, Mr. Nicolardi, and Ivet Bell.

On November 17, the SEC’s Division of Exams released its Exam Priorities for Fiscal Year 2026.  See https://www.sec.gov/files/2026-exam-priorities.pdf.  The Division publishes its exam priorities annually to identify issues that SEC exam staff has identified as potential risks and/or expect to focus on during its upcoming exams of regulated entities.  The 2026 priorities for investment advisers and investment funds include certain topics that have been exam priorities in the past (with some change in emphasis or scope, reflecting the views of new SEC leadership), as well as topics relating to upcoming regulatory changes and topics that respond to significant developments in the asset management industry and markets and to evolving technologies.

A summary of the key 2026 Exam Priorities for investment advisers and investment funds is set forth below.  This summary: highlights changes from prior years’ priorities; discusses the implications of these priorities for investment advisers and investment funds; and outlines the steps that investment advisers and investment funds can take to enhance their compliance functions, manage regulatory risks, and prepare for an SEC exam.

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