On November 17, 2025, the SEC Division of Examinations published its 2026 Examination Priorities. The leadership highlights that the U.S. capital markets are undergoing significant evolution, driven by product innovation, economic and geopolitical developments, as well as changes within the SEC itself. These forces require the Division to refine its approach to examinations while staying grounded in its core mission: promoting compliance, preventing fraud, informing policy, and monitoring risk. The SEC is reevaluating their risk-based priorities and how they approach various trends in the markets, new and emerging products and services, and their processes to ensure examinations continue to be efficient and effective.

Standish comment: Notably, the 2026 priorities did not have nearly the same emphasis on private fund regulation, which is a stark departure from prior years. The limited references to private funds, with only four direct mentions in the whole document, only pertain to newly launched private funds, private fund advisers who also manage separately managed accounts, and advisers that have not previously advised private funds.

The following are highlights of priorities that will mostly directly impact Standish Compliance clients.

• Adherence to Fiduciary Standards of Conduct
• Effectiveness of Investment Advisers’ Compliance Programs
• Never-Examined Advisers and Recently Registered Advisers
• Risk Areas
  • Information Security and Operational Resiliency
    • Cybersecurity
    • Regulation S-ID and Regulation S-P
  • Emerging Technology