---
title: SEC Division of Examinations — Priorities 2022–2026
description: Bates Group's annual chart detailing the SEC Division of Examination's current priorities, in comparison with past years.
---

Bates Group Research

# SEC Division of Examinations — Priorities 2022–2026

Cross-referenced against SEC source documents & Bates annual write-ups  ·  Updated May 2026

Show year:

All

2022

2023

2024

2025

2026

| Priority | 2022 | 2023 | 2024 | 2025 | 2026 |
| --- | --- | --- | --- | --- | --- |
| PROTECTING RETAIL INVESTORS & INVESTORS SAVING FOR RETIREMENT |  |  |  |  |  |
| Marketing Rule 206(4)-1 |  | ✓ | ✓ | ✓ | ✓ |
| Investment Company Act Rule 18f-4 (Derivatives Rule) |  | ✓ | ✓ |  |  |
| Investment Company Act Fair Valuation Rule 2a-5 |  | ✓ | ✓ |  |  |
| Fees and Expenses, Waivers and Reimbursements |  |  | ✓ | ✓ | ✓ |
| Disclosure of Costs of Investing |  |  | ✓ | ✓ | ✓ |
| Conflicts of Interest |  |  | ✓ | ✓ | ✓ |
| Best Execution |  |  | ✓ | ✓ | ✓ |
| Compensation (incentives, sweep programs, breakpoints) |  |  | ✓ | ✓ | ✓ |
| Use of Affiliated Service Providers and Products |  |  | ✓ | ✓ | ✓ |
| Portfolio Management and Trading |  |  | ✓ | ✓ | ✓ |
| Standards of Conduct (Regulation Best Interest) | ✓ | ✓ | ✓ | ✓ | ✓ |
| RIA Fiduciary Duty (Advisers Act Standard) | ✓ | ✓ | ✓ | ✓ | ✓ |
| Form CRS | ✓ | ✓ | ✓ | ✓ | ✓ |
| Suitability and Retail Targeted Investments |  |  | ✓ | ✓ | ✓ |
| Branch Offices and Multi-Branch Advisers |  |  | ✓ | ✓ | ✓ |
| Share Class Selection |  |  | ✓ | ✓ | ✓ |
| Exchange Traded Funds (ETFs) |  |  | ✓ | ✓ | ✓ |
| Municipal Securities and Other Fixed Income Securities | ✓ | ✓ |  | ✓ | ✓ |
| Variable Annuities and Complex Products (derivatives, leveraged/inverse ETFs) |  |  | ✓ | ✓ | ✓ |
| Non-Traded REITs Pricing |  |  | ✓ | ✓ | ✓ |
| Crypto Assets and Associated Products and Services | ✓ | ✓ | ✓ | ✓ |  |
| ESG Investing | ✓ | ✓ |  |  |  |
| Private Fund Advisors | ✓ | ✓ | ✓ | ✓ | ✓ |
| Form PF Reporting (current reporting events) |  |  | ✓ | ✓ |  |
| Special Purpose Acquisition Companies (SPACs) | ✓ | ✓ |  |  |  |
| INFORMATION SECURITY AND OPERATIONAL RESILIENCY |  |  |  |  |  |
| Safeguard Customer Accounts / Prevent Account Intrusions | ✓ | ✓ | ✓ | ✓ | ✓ |
| Oversee Vendors and Third-Party Service Providers | ✓ | ✓ | ✓ | ✓ | ✓ |
| Address Malicious Email Activities / Phishing | ✓ | ✓ |  |  |  |
| Respond to Incidents Including Ransomware Attacks | ✓ | ✓ | ✓ | ✓ | ✓ |
| Identify and Detect Red Flags for Identity Theft | ✓ | ✓ |  | ✓ | ✓ |
| Compliance with Regulations S-P and S-ID | ✓ | ✓ | ✓ | ✓ | ✓ |
| Manage Operational Risks / Work From Home | ✓ |  |  | ✓ |  |
| Business Continuity, Disaster Recovery, and Climate Risk | ✓ |  |  |  |  |
| Cybersecurity — General Elevated Risk Environment |  |  | ✓ | ✓ | ✓ |
| FINANCIAL TECHNOLOGY AND DIGITAL ASSETS |  |  |  |  |  |
| Electronic / Automated Investment Advice (Robo-Advisers) | ✓ | ✓ | ✓ | ✓ |  |
| Digital Engagement Practices (Finfluencers, gamification, behavioral prompts) | ✓ | ✓ | ✓ | ✓ |  |
| Emerging Financial Technology |  |  | ✓ | ✓ | ✓ |
| RegTech |  |  |  | ✓ | ✓ |
| Artificial Intelligence (AI) |  |  | ✓ | ✓ | ✓ |
| Creation, Use, and Receipt of Alternative Data / MNPI Controls | ✓ | ✓ | ✓ | ✓ | ✓ |
| ASSESSING MARKET-WIDE RISKS |  |  |  |  |  |
| Clearing Agencies | ✓ | ✓ | ✓ | ✓ | ✓ |
| FINRA | ✓ | ✓ | ✓ | ✓ | ✓ |
| MSRB | ✓ | ✓ | ✓ | ✓ | ✓ |
| National Securities Exchanges | ✓ | ✓ | ✓ | ✓ | ✓ |
| Regulation Systems Compliance and Integrity (Reg SCI) | ✓ | ✓ | ✓ | ✓ | ✓ |
| Liquidity Risk and Controls |  | ✓ | ✓ | ✓ | ✓ |
| Potential Equity Order Routing Conflicts |  |  |  | ✓ | ✓ |
| Money Market Funds | ✓ |  |  |  |  |
| ANTI-MONEY LAUNDERING AND SANCTIONS |  |  |  |  |  |
| Anti-Money Laundering (AML) | ✓ | ✓ | ✓ | ✓ | ✓ |
| OFAC / Treasury Sanctions Compliance |  | ✓ | ✓ | ✓ | ✓ |
| Microcap Fraud | ✓ |  |  |  |  |
| Recidivist Representatives | ✓ |  |  |  |  |
| BROKER-DEALER AND EXCHANGE EXAMINATION PROGRAM |  |  |  |  |  |
| Broker-Dealer Financial Responsibility (Customer Protection Rule, Net Capital Rule) | ✓ | ✓ | ✓ | ✓ | ✓ |
| Cash Sweep Programs and Prime Brokerage (concentration, liquidity, counterparty credit) |  |  |  |  | ✓ |
| Broker-Dealer Trading Practices | ✓ | ✓ | ✓ | ✓ | ✓ |
| Electronic Communications Recordkeeping (off-channel compliance) |  | ✓ | ✓ |  |  |
| Reg SHO, Reg ATS, Form ATS-N | ✓ | ✓ | ✓ | ✓ | ✓ |
| T+1 Settlement Cycle (Rules 15c6-1 and 15c6-2 Compliance) |  |  | ✓ | ✓ |  |
| Extended Hours Trading |  |  |  |  | ✓ |
| Security-Based Swap Dealers (SBSDs) | ✓ | ✓ | ✓ | ✓ | ✓ |
| Regulation NMS Rule 605 (Order Routing Disclosures) |  |  |  |  | ✓ |
| Security-Based Swap Execution Facilities (SBSEFs) |  |  |  | ✓ | ✓ |
| Funding Portals |  |  |  | ✓ | ✓ |
| OTC / Microcap Securities Compliance | ✓ | ✓ |  |  |  |
| Municipal Advisors | ✓ | ✓ | ✓ | ✓ | ✓ |
| Transfer Agents | ✓ | ✓ | ✓ | ✓ | ✓ |
| INVESTMENT ADVISER AND INVESTMENT COMPANY PROGRAM |  |  |  |  |  |
| RIA Compliance Programs |  |  | ✓ | ✓ | ✓ |
| Activist Engagement — Schedules 13D/13G, Form 13F, Forms 3/4/5, Form N-PX |  |  |  |  | ✓ |
| Registered Funds Including Mutual Funds and ETFs | ✓ | ✓ | ✓ | ✓ | ✓ |
| Fund Names Rule Compliance (Rule 35d-1) |  |  |  |  | ✓ |
| Calculation of Fees and Expenses (incl. private fund fees, illiquid assets) | ✓ | ✓ | ✓ | ✓ | ✓ |
| Never-Before-Examined Investment Advisers and Companies | ✓ | ✓ | ✓ | ✓ | ✓ |
| M&A / Consolidation of Advisory Firms (conflicts and operational complexity) |  |  |  |  | ✓ |
| Business Development Companies (BDCs) | ✓ |  |  |  |  |
| Broker-Dealer Accounts Converted to Advisory | ✓ |  | ✓ | ✓ | ✓ |
| Dual Registrant Wrap Fee Programs |  |  | ✓ | ✓ | ✓ |
| LIBOR Transition | ✓ | ✓ |  |  |  |
| Alternative Investment Companies |  |  |  | ✓ | ✓ |
| Fixed Income Investment Companies |  |  |  | ✓ | ✓ |

 No matching priorities found.

✓

 Confirmed stated priority

 Not a stated priority that year

 Sources: SEC Division of Examinations FY2022–FY2026 Examination Priorities documents. Bates Group annual alerts 2022–2026. Data sourced from "2022-2026 Corrected" worksheet.