Yearly Archives: 2026

2026 SEC Division of Examinations Priorities

Kristin Snyder, Charu Chandrasekhar, and Sheena Paul are Partners at Debevoise & Plimpton LLP. This post is based on their Debevoise memorandum.

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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Would Your Company Want To Stop Filing Quarterly Reports if No Longer Required?

Anita Bandy, Elizabeth R. Gonzalez-Sussman, and Raquel Fox are Partners at Skadden, Arps, Slate, Meagher & Flom LLP. This post is based on a Skadden memorandum by Ms. Bandy, Ms. Gonzalez-Sussman, Ms. Fox, and Caroline S. Kim.

Key Points

  • The Trump administration and the SEC say they want to eliminate the need for quarterly financial reports by public companies, a move that would reduce the regulatory burden on companies and encourage more long-term thinking.
  • But a number of factors could cause companies to continue to report more often than semiannually, including shareholder demands, the prospect of activist pressure and the possibility that less frequent reporting would result in less analyst coverage.
  • Changing to semiannual reporting could also complicate capital raising, share buybacks and trading windows for insiders.

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ISS Publishes 2026 Benchmark Policy Changes

David A. Bell, Ran Ben-Tzur, and Elizabeth Gartland are Partners at Fenwick & West LLP. This post is based on their Fenwick memorandum.

What You Need To Know

  • Institutional Shareholder Services (ISS) has released its benchmark voting policy updates for 2026, with notable shifts in board accountability for capital structures and responsiveness, executive compensation assessments, evaluation of equity plans, and ISS’s approach to key environmental and social shareholder proposal topics.
  • The updated policies will generally apply to shareholder meetings taking place after February 1, 2026.

ISS updated its benchmark proxy voting policies on November 25, 2026. The updates applicable to U.S. companies are briefly summarized below.

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Weekly Roundup: December 26-Jan 1, 2026


More from:

This roundup contains a collection of the posts published on the Forum during the week of December 26-Jan 1, 2026

Emergency Challenge to Continuation Fund Deal Lands in Delaware Court


Corporate Sustainability: Emissions, Governance, and the Energy Transition


BDO’s 2025 Board Survey


Preparing for Proxy Season 2026


SEC & Mandatory Arbitration: Policy Evolution and Supreme Court Precedent


CEO and Executive Compensation Practices in the Russell 3000 and S&P 500


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