Key SEC Examination Priorities for 2025

As we approach 2025, it’s essential for firms to stay informed about the SEC’s examination priorities, which continue to evolve. While many priorities remain consistent with previous years, new focal points have emerged that firms should be aware of. Here’s Quadrant’s key takeaways of the SEC’s examination priorities for the upcoming year:

Investment Adviser

• Fiduciary Standards: Emphasis on adherence to fiduciary standards of conduct.
• Compliance Program Effectiveness: Evaluation of the effectiveness of advisers’ compliance programs.
• Private Fund Examinations: Increased scrutiny of advisers managing private funds.
• Targeting the Underserved: Focus on advisers who have never been examined, those recently registered, and advisers who have not been recently reviewed.

Broker-Dealers

• Regulation Best Interest Compliance: Ensuring compliance with Regulation Best Interest.
• Form CRS Accuracy: Examination of the accuracy and completeness of Form CRS (Customer Relationship Summary).
• Financial Responsibility Rules: Adherence to financial responsibility rules for broker-dealers.
• Trading Practices: Review of trading-related practices and services.

Clearing Agencies

• Annual Risk Assessments: Focus on core risks, processes, and controls, including compliance with the SEC’s Standards for Covered Clearing Agencies.

Risk Areas Impacting Market Participants

• Information Security: Evaluating information security practices and operational resiliency, including cybersecurity measures.
• Regulatory Compliance: Adherence to Regulations S-ID and S-P.
• Settlement Cycle Adaptation: Preparing for the shortened settlement cycle.
• Emerging Technologies: Integration of financial technologies, including AI and digital engagement methods.
• Crypto Assets: Oversight of activities involving crypto assets.
• Systems Compliance: Compliance with Regulation Systems Compliance and Integrity (SCI).
• Anti-Money Laundering (AML): In-depth analysis of AML programs and related compliance.

For a complete overview of the SEC’s examination priorities for 2025, please visit the SEC’s official publication.