The SEC’s FY 2027 examination priorities send investment advisers a clear message: compliance programs must reflect how firms actually operate. Examiners will focus on:

• Conflicts of interest: Fees, compensation, and whether practices match disclosures.
• Private funds: Illiquid assets, allocations, borrowing, and fee and expense practices.
• Compliance programs: Especially at firms with recent acquisitions, growth, or new strategies.
• AI, cybersecurity, and vendors: Technology disclosures and third-party access to client data.
• Proxy and reporting: Proxy adviser oversight and beneficial ownership filings.

Never-examined and newly registered advisers remain a priority. CCOs should use this roadmap to find gaps before examiners do. To help you make sense of what this means for you and your clients, read the full article from our friends at SEC³ here.