The SEC Division of Examinations (“Examination Division” or “Division”) published its 2025 Examination Priorities, highlighting the 30th anniversary of the creation of the Division (originally called the Office of Compliance Examinations & Inspections, or OCIE). The priorities memo summarized changes in the industry since that date and ways that the Division has adapted its program, improved communication and transparency, and directed its resources to critical risk areas. The Division outlined its priorities across all of its registrant base, including 1) investment advisers (RIAs and ERAs); 2) investment companies; 3) broker-dealers; 4) self-regulatory organizations; 5) clearing agencies; and 6) other market participants. The Division further summarized its examination efforts related to key risk areas and regulatory developments and stated that it will prioritize examinations of investment advisers that have never been examined and those that have not recently been examined. We have summarized priorities that will most directly impact Standish Compliance clients, including the following:

• Fiduciary Standards of Conduct
• Compliance Programs
• Private Fund Advisers
• Cybersecurity
• Privacy & Regulation S-P
• T+1 Settlements
• Emerging Financial Technologies
• Crypto Assets
• Anti-Money Laundering

We expect that SEC staff will discuss the 2025 priorities in greater detail in its National Compliance Outreach Seminar this Thursday, November 7, 2024. We encourage clients to watch the event online. A link to the live webcast will be made available the morning of Nov. 7 on www.SEC.gov. The Standish Compliance team will work with clients to prepare for and manage examinations incorporating these priorities.