SEC FY2027 Exam Priorities Add AI-Threat and Cross-Border Scrutiny
The SEC Division of Examinations' FY2027 priorities keep conflicts, fees, private credit and Reg BI in focus, and add explicit scrutiny of AI-driven cyber threats, tokenization and cross-border pump-and-dump activity.
On October 23, 2026, the SEC Division of Examinations published its Fiscal Year 2027 examination priorities, signaling where examiners will concentrate review resources in the coming year. For registered investment advisers, the Division maintains its focus on fiduciary duty, economic conflicts of interest and compliance-program effectiveness, with particular attention to advisers recommending illiquid or complex products (private credit, BDC loans, option-based and inverse ETFs) and to firms that recently merged, changed business models or run dispersed branch offices. Registered investment companies face scrutiny on fees and waivers, valuation and redemption practices in funds holding private credit, and leveraged fund structures. Broker-dealer exams will emphasize the Net Capital and Customer Protection Rules, extended-hours trading and liquidity, and Regulation Best Interest, including Form CRS content. Two elements are comparatively new: a cross-reference to the SEC Cross-Border Task Force's work on pump-and-dump and ramp-and-dump activity in foreign-based securities within AML exams, and an explicit "super intelligence" module covering AI-generated phishing, deepfake social engineering and ransomware, alongside Regulation SCI scrutiny of tokenization and quantum computing. Counsel should treat this as an exam-readiness checklist: benchmark conflicts, fee disclosure and AML programs now, and confirm Regulation S-P and S-ID programs reflect SI-driven threat scenarios.