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SEC Chair Paul Atkins has described examinations as a constructive dialogue rather than a gotcha exercise. The distinction is important, but it is easy to misinterpret. A more collaborative tone does not signal a retreat from oversight; it reflects a different philosophy of supervision—one that assumes firms are capable of explaining, evidencing, and defending their compliance programs without the need for an adversarial backdrop.
The mechanics of examination remain unchanged. The Division of Examinations still sets priorities, selects firms for review, and arrives with a request letter. What has changed is the posture. A collaborative approach places an importance on credibility, requiring firms to demonstrate that their policies are not merely documented but operationalized through effective controls and day-to-day practice. The standard remains the same: what appears on paper must withstand scrutiny when tested against reality.
A Softer SEC Exam Still Demands Proof
A softer exam is not a lighter one. Examiners still expect you to substantiate, in detail, the program you describe in your manuals. What they want is evidence that your controls operate as designed, not a well-written compliance manual. Expect them to ask for:
- Testing records that show a control ran when it was supposed to
- Review dates documenting when policies were last assessed, and by whom
- Supporting documentation that ties the two together into a complete trail
Firms that lean on a well-drafted policy without maintaining the records behind it often find the gap mid-exam, which is the worst place to find one.
New Rules, New Blind Spots
The biggest gaps tend to come from rules that did not exist at your last exam. Two areas stand out this year:
- The Regulation S-P amendments are fully in effect for firms of every size, and they carry obligations that many existing compliance programs were never built to address.
- “AI washing” has become a live enforcement theme, with examiners testing whether a firm’s stated capabilities match what technology can do.
If your last examination predates either one, there is a good chance you are behind and may not realize by how much.
The Standing Priorities Haven’t Moved
Most programs do not fail because the firm never built them. They fail because they weren’t maintained. The areas that have anchored the SEC’s priorities for years are still the ones examiners probe first:
- Fiduciary duty and conflicts of interest sit at the top of the list. Naming your conflicts in a policy is where the work starts, not where it ends.
- The Marketing Rule shifted with the 2025 FAQ guidance, which gave advisers meaningful relief, but only for the firms that updated their reviews to match.
- Custody obligations move as the business takes on new relationships and authorizations.
These are not dramatic breakdowns. They are the quiet failures that accumulate between exams, and the ones examiners know exactly how to find.
A First SEC Exam Is Still on the Table
Never-examined and recently registered advisers remain a standing priority. For regulators, a lack of exam history creates questions, not comfort. If your firm has never been through an exam, that is the argument for finding your gaps now, on your terms, before an examiner does it for you.
Readiness Doesn’t Take a Year Off
A quieter environment changes how an exam feels. It does not take the exam off your calendar. The greatest risk falls on firms that mistake a lighter touch for a lower standard and keep coasting until the letter lands.
Our 2026 SEC Exam Readiness Checklist breaks every focus area above into the specific items examiners look for, so you can find out where you stand before they tell you.