From conflicts of interest to emerging technology, the SEC’s priorities underscore the importance of consistent oversight, clear accountability, and compliance programs that keep pace with business change.
The SEC’s Division of Examinations released its Fiscal Year 2027 Examination Priorities on October 23, 2026, highlighting fiduciary obligations, retail investor protection, supervision, cybersecurity, emerging technologies, and evolving market infrastructure. The agenda spans investment advisers, investment companies, broker-dealers, and other market participants, with attention to activities that present heightened risks to investors or market integrity.
For compliance leaders, the focus is on execution: translating policies into consistent processes, assigning clear ownership, and maintaining documentation that shows how risks are identified, managed, and resolved.
Importantly, the priorities are not new rules or an exhaustive examination checklist. They represent staff views, create no new legal obligations, and may shift as risks and market conditions evolve. Firms should use them to inform a risk-based assessment, not as a substitute for evaluating the full range of obligations applicable to their businesses.
1. Conflicts of Interest Remain Central to Investor Protection
The SEC identifies investment advisers’ fiduciary obligations, conflicts of interest, investment recommendations, and compliance programs as key examination areas for FY 2027.
Effective conflicts oversight extends from initial disclosure through review, mitigation, and ongoing monitoring. Collecting a disclosure is a starting point. The more consequential questions are whether the firm understands the potential impact, determines an appropriate response, and follows through when circumstances change.
A useful assessment should consider:
- Whether disclosures capture enough information to support meaningful review.
- How potential conflicts are escalated and evaluated.
- Whether restrictions or other mitigation measures receive ongoing oversight.
- How changes in business activities, relationships, or compensation trigger reassessment.
Employee disclosures are one component of this work. Firms also need to assess broader economic and business conflicts that could affect advice, recommendations, or client outcomes.
Managing that lifecycle requires a consistent process for routing submissions, documenting reviews, monitoring exceptions, and reassessing previously approved activities. RegEd offers a range of Conflicts of Interest solutions that support these processes through hierarchy-based approval workflows, periodic attestations, automated alerts, and enterprise reporting. These capabilities help compliance teams maintain visibility into employee activities and produce documentation showing how potential conflicts were reviewed and addressed.
2. Complex Products and Reg BI: Connect Recommendation Oversight With Training
Retail investor protection remains a prominent theme, particularly for complex, higher-risk, and illiquid products. The priorities also highlight private funds, private credit, and other complex investment strategies.
For broker-dealers, the priorities address Regulation Best Interest (Reg BI), including product and investment strategy recommendations, account and rollover recommendations, and products such as variable annuities and registered index-linked annuities.
These areas call for coordination across product due diligence, recommendation oversight, disclosures, training, and supervisory review. Firms should assess whether financial professionals understand the products they recommend and whether communications explain material limitations as clearly as potential benefits.
For annuity business, that assessment should also address how applicable licensing, appointment, and training requirements are verified before sales activity occurs.
Connecting training records with credential verification can help firms reduce gaps between completing a requirement and confirming readiness to transact. RegEd’s Annuities Training Platform centralizes required state and carrier-specific product training and reports completions to affiliated carriers and distributors. RegEd CLEARXchange extends that process by validating contracting, licensing, education and training, appointments, and registration at the source to deliver a real-time Clear to Sell determination. Together, these capabilities reduce reliance on manual checks and delayed training reports while supporting more consistent readiness verification.
These operational controls complement, rather than replace, the firm’s assessment of whether a recommendation satisfies its Reg BI obligations.
3. Compliance Programs Should Evolve With the Business
The investment adviser compliance program priorities specifically address advisers that have grown through mergers, acquisitions, or other means, as well as those operating from geographically dispersed branch offices.
Growth can introduce different procedures, systems, supervisory practices, and recordkeeping processes. A firm may operate under one name while continuing to manage compliance through disconnected practices inherited from predecessor businesses.
The practical question is whether the compliance program functions consistently across the organization.
A focused review should examine whether:
- Policies reflect the combined firm’s current activities and risks.
- Branches follow consistent review and escalation processes.
- Audit and testing activities identify differences in local execution.
- Registration records reflect changes in personnel and organizational structure.
- Corrective actions are assigned, tracked, and verified.
As firms expand, centralized oversight can help prevent local practices from becoming disconnected compliance processes. RegEd’s Branch Audit Management supports inspection scheduling, configurable audit content, program dashboards, and integrated remediation, including identification of repeat deficiencies. Policies & Procedures Management complements that oversight with a central policy repository, role-based distribution, version control, and a full history of revisions. These capabilities help firms establish consistent standards across locations and track whether identified gaps are resolved.
Growth also increases the complexity of registration maintenance. RegEd’s Xchange Licensing & Registration centralizes securities registration activities, including Form U4, Form U5, and Form BR management, FINRA integration, and automated workflows. This supports coordinated registration oversight as firms add representatives and branches.
The priorities address the accuracy of disciplinary disclosures concerning firms and their financial professionals. For municipal advisors, they also identify professional qualification, registration, recordkeeping, and supervision requirements.
4. Registration and Disclosure: Keep Records Aligned With Current Information
These focus areas reinforce the importance of connecting employee reporting with registration and disclosure processes. Information collected through a questionnaire or outside business activity disclosure needs to reach the teams responsible for determining whether a regulatory filing or other update is necessary.
Firms should assess how they:
- Identify changes that may require registration or disclosure updates.
- Reconcile employee attestations with existing regulatory records.
- Route potential amendments for review and submission.
- Maintain documentation supporting updates and supervisory decisions.
- Keep applicable adviser disclosures, including Form ADV Part 2B, current.
Accurate disclosures depend on connecting employee reporting with the records and workflows used to maintain regulatory filings. RegEd’s Compliance Questionnaires can prepopulate questionnaires with FINRA data so representatives can review and confirm information already on file, while configurable workflows route responses requiring attention for further review. Outside Business Activities connect disclosure submissions, supervisory approvals, and FINRA Form U4 amendment filing and reconciliation, with an audit trail documenting the chronology of each request.
For investment advisers, RegEd’s Form ADV Part 2B Supplement uses existing representative data to streamline collection, verification, approval, and supplement creation. Connecting these activities helps firms reduce duplicate entry and maintain a clearer record of how reported changes are reviewed and reflected in applicable disclosures.
5. Emerging Technology: Establish Documented, Accountable Supervision
The report uses the term “super intelligence” when discussing advanced technologies and describes their growing use across research, drafting, client communications, portfolio management, and compliance monitoring. It emphasizes that firms remain subject to existing, technology-neutral obligations.
For firms adopting AI and other advanced tools, governance needs to extend beyond evaluating the technology itself. Firms should be able to explain where a tool is used, who is accountable, what review is required, and how exceptions are addressed.
A practical governance framework should include:
- An inventory of approved use cases and accountable owners.
- Policies and procedures proportionate to each use case’s risks.
- Defined human review and escalation requirements.
- Testing and monitoring appropriate to the tool’s function.
- Version histories showing which procedures applied during a given period.
As AI use evolves, firms need to maintain not only current procedures but also a record of how those procedures changed. RegEd’s Policies & Procedures Management provides a centralized repository, role-based distribution, archived policy versions, and a full audit trail of revisions. Applied to AI governance, these capabilities can help firms document the procedures governing approved uses and identify which version was in effect during a particular period. The value is a more traceable governance process as tools, responsibilities, and controls evolve.
The objective is to capture efficiency gains while maintaining clear accountability and supportable oversight.
6. Cybersecurity and Third Parties: Connect Vendor Oversight With Incident Response
The SEC highlights cybersecurity, operational resiliency, and protection of customer information. The report also identifies Regulation S-ID and Regulation S-P within its cross-market risk areas.
Third-party service providers and shared technologies add dependencies that firms need to understand and manage. Firms should assess what information and systems providers can access, how responsibilities are allocated, and how incidents are escalated.
Effective oversight connects vendor review with ongoing monitoring and incident response. That includes documenting assessments, identifying dependencies, and establishing procedures for coordinating when an issue affects client information or business operations.
Platform consolidation may simplify some oversight activities, but firms should also evaluate concentration risk and operational dependencies. Fewer providers do not automatically mean lower risk.
Third-party oversight and incident response depend on clear procedures that remain accessible and current across the teams responsible for carrying them out. RegEd’s Policies & Procedures Management supports centralized documentation, distribution by role, and revision histories. For firms managing vendor-related risks, these capabilities can support consistent access to approved escalation and response procedures and provide a record of how those procedures have changed over time.
7. Market Infrastructure: Assess Exposure and Assign Ownership
The priorities also address evolving market infrastructure, including Treasury clearing reforms and tokenization, alongside oversight of self-regulatory organizations and other critical market participants.
The implications will differ by firm. An applicability assessment should consider direct activities as well as dependencies on counterparties, clearing arrangements, service providers, and technology.
Where a development is relevant, firms should identify affected processes, assign ownership, and determine whether systems, procedures, or training need to change.
A structured change-management process helps firms move from identifying a development to determining applicability, assigning responsibility, and documenting implementation. RegEd’s Regulatory Change Management combines regulatory monitoring and analysis with routing, task management, and reporting. Within the firm’s subscribed coverage, these capabilities help teams assess relevant changes, coordinate resulting work, and maintain an audit trail of actions taken.
Turning the Priorities Into a Practical Action Plan
Firms can translate the priorities into action through a focused review of risks, controls, and compliance processes:
- Map relevant priorities to business activities and existing controls.
- Identify gaps in execution, ownership, or supporting evidence.
- Prioritize testing based on risk and potential investor impact.
- Assign corrective actions with clear deadlines and escalation paths.
- Verify that remediation addresses the underlying issue.
Examination readiness depends on more than having policies in place. Firms need clear ownership, consistent execution, and visibility into how issues are addressed. Connecting these processes helps compliance teams reduce gaps in oversight and demonstrate how their programs operate in practice.
RegEd helps firms connect these responsibilities across conflicts of interest, registration, training, advertising review, audit and exam management, regulatory change, and policies and procedures. A more connected compliance framework supports stronger oversight, reduces manual effort, and helps teams track issues from identification through resolution.
Explore how RegEd can help your firm strengthen oversight and simplify compliance processes. Schedule an introductory conversation to learn more.
This article is for informational purposes only and does not constitute legal advice.
About RegEd
RegEd is the market-leading provider of RegTech enterprise solutions with relationships with more than 200 enterprise clients that represent 80% of the top 25 financial services firms.
Established in 2000 by former regulators, the company is recognized for continuous regulatory technology innovation with solutions hallmarked by workflow-directed processes, data integration, regulatory intelligence, automated validations, business process automation and compliance dashboards. The aggregate drives the highest levels of operational efficiency and enables our clients to cost-effectively comply with regulations and continuously mitigate risk.
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