Investment advisers' financial conflicts, complex investments sold to ordinary investors and the security of customer information are among the SEC examination staff's priorities for fiscal 2027. The SEC announced the agenda October 23.
Advisers' fees and recommendations
The Division of Examinations says it will prioritize whether advisers meet their duties to clients, particularly retail and older investors, including people saving for retirement. Reviews will examine disclosures, product research, compliance procedures and valuation methods.
Staff plans to assess whether advisers' financial conflicts may affect the impartiality of their advice in areas such as fee rebates, fee and expense calculations, cash management, deposits or withdrawals. It will also examine whether recommended products fit clients' objectives, risk tolerance and other requirements.
Advisers recommending products that are difficult to trade, have unusual features or are illiquid are a priority. Examples include private-fund loans, investments in private companies through special-purpose vehicles and certain complex exchange-traded funds. Illiquid investments can be difficult to sell.
For private funds, planned reviews include risk disclosures, use of debt, affiliated service providers, and fee and expense calculations at both fund and investment levels.
Customer information and sales practices
Broker-dealer examinations will review recommendations involving complex or higher-risk products and recommendations made to older and vulnerable investors or people saving for retirement or college. Reviews will also cover relationship summaries describing services, fees, conflicts and disciplinary history.
Cybersecurity examinations will consider access controls, data-loss prevention and responses to incidents such as ransomware attacks. Staff also plans to assess risks from third-party providers and shared technology.
What the agenda establishes
The SEC says the program spans more than 34,000 registrants, including advisers, investment companies, broker-dealers and other market participants. That is the program's scope, not a promise to examine every registrant this year.
The PDF expressly represents staff views. It has no legal force or effect, changes no applicable law and creates no additional obligations. The priorities are not exhaustive and may shift as risks change. They do not establish that any named investment or firm has violated the law.