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SEC Exam Priorities for 2025

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The SEC’s Division of Examinations (commonly known as EXAMS) is the oversight branch of the Securities and Exchange Commission. It’s the second largest section of the agency, after the enforcement arm.

The Division of Examinations uses a variety of inspections and examinations to make sure that companies and other market participants are following the SEC’s rules with the mission to protect investors and monitor risk, among other objectives.

Through its on-site examination process, agency representatives review how well a market participant is complying with SEC regulations, how it manages risk and transparency and other critical issues.

Each year, the Division of Examination sets its examination priorities for the year ahead. While these are not necessarily exhaustive, the announced priorities show what the SEC examiners will pay specific attention to while they review a company’s operations. 

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EXAMS Priorities for 2025

The SEC’s Division of Examinations (EXAMS) has outlined its priorities for the 2025 fiscal year, focusing on several key areas to ensure compliance and protect investors. For full details on these priorities, see the SEC’s linked summary.

Investment Advisors

EXAMS will assess investment advisers’ adherence to fiduciary standards, particularly in their recommendations of high-cost or illiquid investments. The effectiveness of advisers’ compliance programs will be evaluated, with attention to fee calculations and disclosures. Advisers to private funds will undergo scrutiny regarding fee allocations, conflicts of interest and compliance with recent SEC rules. Additionally, advisers who are newly registered or have not been examined recently will be prioritized.

Investment Companies

The SEC will examine investment companies for compliance with regulations, accuracy of disclosures and fee structures. There will be a focus on funds investing in illiquid or difficult-to-value assets, such as commercial real estate, to ensure proper valuation and risk management practices.

Broker-Dealers

Examinations will focus on compliance with Regulation Best Interest and Form CRS, evaluating whether broker-dealers act in the best interest of retail customers and provide clear disclosures. Financial responsibility rules, including net capital and customer protection, will be assessed. Trading-related practices, especially those involving complex or high-risk products, will also be reviewed.

Self-Regulatory Organizations

National securities exchanges and organizations like FINRA and the Municipal Securities Rulemaking Board will be examined to ensure they enforce compliance with their rules and federal securities laws. This includes assessments of governance, regulatory programs and market oversight functions.

Clearing Agencies

Registered clearing agencies, particularly those deemed systemically important, will be reviewed for their risk management frameworks, including liquidity, margin systems and default management. The SEC will assess their compliance with the Securities Exchange Act and the effectiveness of their remediation efforts for prior deficiencies.

Other Market Participants

Municipal advisors, transfer agents, security-based swap dealers and funding portals will be examined for compliance with applicable regulations, fiduciary duties and risk management practices. This includes evaluations of their policies, procedures and operational controls.

Risk Areas Impacting Various Market Participants

Information security remains a significant focus, with examinations assessing cybersecurity policies, data protection measures and incident response plans. The SEC will engage with firms regarding their preparedness for the amended Regulation S-P, which requires incident response programs to detect, respond to and recover from unauthorized access to customer information.

The SEC will also evaluate compliance with the shortened settlement cycle under Rule 15c6-1, the use of emerging financial technologies, involvement with crypto assets, adherence to Regulation Systems Compliance and Integrity, as well as anti-money laundering programs.

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Bottom Line

Every year the SEC publishes its examination priorities for regulated entities. This year it has published its 2025 priorities so that investment advisors, broker-dealers and investors can begin to prepare for the next round of annual examinations. 

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