SEC Releases 2025 Examination Priorities

The Securities and Exchange Commission (SEC) Division of Examinations released its 2025 Examination Priorities which focus on areas such as fiduciary duty, standards of conduct, cybersecurity, and artificial intelligence. The Division will conduct exams in “core areas” such as governance practices and disclosure, but also compliance with newly adopted rules, the use of emerging technologies, and controls that protect investor information, records, and assets. For registered investment companies, the Exams staff highlight the following areas of focus:

• Compliance programs, disclosures, and governance practices;
• Fund fees and expenses, and any associated waivers and reimbursements;
• Oversight of service providers (both affiliated and third-party);
• Portfolio management practices and disclosures, for consistency with claims about investment strategies or approaches and with fund filings and marketing materials;
• Issues associated with market volatility;
• Exposure to commercial real estate; and,
• Compliance with new and amended rules.

The press release notes, however, that the scope of examinations further depends on “analysis of other risk factors such as an entity’s history, operations, and products and services.” Funds that have not been examined previously and funds that are newly registered may be a focus. SEC Chair Gary Gensler noted the priorities set forth by the Division “enhance trust in our ever-evolving markets.”

Click here to read the SEC’s 2025 Examination Priorities.
Click here to read the SEC press release covering the Examination Priorities.