SEC Sets 2027 Exam Priorities With Focus on Conflicts, Complex Products, and Technology

In an article published by the Harvard Law School Forum on Corporate Governance, Sidley partners Chuck Daly, Ranah Esmaili, and Lara Mehraban examine the U.S. Securities and Exchange Commission’s (SEC) 2027 examination priorities and their implications for investment advisers, investment companies, broker-dealers, and other market participants. The authors highlight the SEC’s continued focus on fiduciary obligations, economic conflicts of interest, private credit and other complex investment products, and emerging technologies, including artificial intelligence (AI).

The article also outlines key compliance considerations for financial services firms preparing for SEC examinations, including reviews of fee and expense practices, valuation methodologies, AI governance, cybersecurity controls, and regulatory obligations under Regulation Best Interest and Regulation S-P.

Sidley lawyers Kathryn Alessi, Hardy Callcott, and Kenyon Hall contributed to this article.