| 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) | ✓ | ✓ | ✓ | ✓ | ✓ |
| Software Supply Chain Risk (secure code development, SCI entities) | ✓ | ||||
| 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 | ✓ | ✓ | ✓ | ✓ | ✓ |
| Large Trader Reporting Obligations | ✓ | ||||
| T+1 Settlement Cycle — Rules 15c6-1 and 15c6-2 Compliance | ✓ | ✓ | |||
| Payment for Order Flow / Order Routing Conflicts | ✓ | ||||
| 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 | ✓ | ✓ | |||
✓
Confirmed stated priority✓
Corrected from prior chart — hover for detail Not a stated priority that year
Sources: SEC Division of Examinations FY2022–FY2026 Examination Priorities documents.
Bates Group annual alerts 2022–2026. Corrections based on cross-reference analysis of source documents.
Hover over yellow cells or the ⓘ icon for correction notes.