As the Division of Examinations of the Securities and Exchange Commission (SEC) unveiled its 2025 examination priorities, a broad spectrum of issues for registered investment advisers, investment companies, and broker-dealers comes into focus. Published on October 21, 2024, this document underscores significant themes expected to resonate throughout the upcoming year.

The priorities, while reflecting potential shifts due to the changing presidential administration, maintain steadfast core areas, suggesting continuity in enforcement actions. A comprehensive review highlights the Division’s focus on private fund advisers, cybersecurity, and the utilization of artificial intelligence, emphasizing long-standing commitments alongside new regulatory amendments.

Investment Advisers

For investment advisers, the SEC will enhance oversight on those who have never undergone an examination or have been recently registered. Key review components will include fiduciary standards, compliance programs, and private fund advisers, particularly in volatile markets like commercial real estate and crypto assets.

Broker-Dealers

Broker-dealers will be scrutinized regarding Regulation Best Interest (Reg BI) and Form CRS obligations. The focus will be on assessing the alignment of broker-dealer practices with customer interests, especially concerning complex and high-risk products.

Risk Areas and Technology

Cybersecurity remains a cornerstone in the SEC’s examination strategy, ensuring entities have robust governance and protection measures. Similarly, the rise of artificial intelligence and its integration into financial services draws sharp scrutiny to ensure compliance and mitigate potential risks.

In conclusion, while the 2025 examination priorities from the SEC provide a roadmap for regulatory focus, they also serve as a vital tool for entities to self-evaluate and reinforce their compliance frameworks against potential risks, safeguarding investors and market integrity.

For more information, view the full article on Stinson LLP’s website.

Authored by Eric Mikkelson & Carissa Occhipinto, Stinson LLP