Key Takeaways:

• On November 17, 2025, the U.S. Securities and Exchange Commission’s (the “SEC”) Division of Examinations (the “Division”) released its 2026 Examination Priorities (the “Priorities”). As in prior years, the Priorities provide insight into the products, practices, and services the Division views as presenting heightened risk to investors or the broader markets and expects to focus on in upcoming examinations.
• The 2026 Priorities reflect both continuity and evolution. While the Division continues to emphasize long-standing themes—such as fiduciary duties, conflicts of interest, fee and expense practices, and retail investor protection—the Division also highlights emerging areas of focus, including cybersecurity and operational resiliency, firms’ use of artificial intelligence and other automated technologies, and preparedness for the upcoming amendments to Regulation S-P. Notably, although crypto assets are absent from this year’s Priorities for the first time since 2018, the Division continues to focus on alternative investments, including private credit, and incorporates private fund issues into broader thematic review areas rather than a standalone section.
• The 2026 Priorities also underscore continued oversight of market infrastructure and other market participants, including security-based swap dealers and, for the first time, security-based swap execution facilities. The Division similarly maintains its focus on funding portals, municipal advisors, broker-dealers’ trading and sales practices, and RICs—particularly those employing complex strategies, holding less-liquid assets, or navigating mergers or similar transactions.

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