The SEC Just Told You Its 2026 Exam Playbook. Are You Ready?
The SEC’s Division of Examinations has released its 2026 exam priorities, and the message is clear: fiduciary duty, private credit, complex products, cybersecurity, and fintech and AI are all moving to the center of the regulatory radar. At the same time, the agency is stepping back from a dedicated crypto focus and instead folding digital assets into a broader emerging-technology review. For broker-dealers and RIAs, this is not just another priorities list; it is a practical roadmap for what your next exam is going to look like and where exam teams will expect real evidence, not promises.
GiGCXOs is already aligning its consulting and reg-tech platforms with its AICompliance360 product, around these 2026 themes. The key is translating the SEC’s priorities into concrete exam risk and then building processes, documentation, and technology that show you are actually living your policies, not just publishing them.
Fiduciary Duty and Reg BI: Beyond Check-the-Box
For RIAs, the SEC is doubling down on fiduciary standards: duty of care, duty of loyalty, best execution, and real-world management of conflicts and fees. Examiners are going to dissect recommendations, disclosures, and fee arrangements, looking for whether the client truly comes first in practice. Newly registered advisers and firms that have never been examined will be under particular scrutiny, as exam teams look to see whether first-generation compliance programs are truly robust or essentially templates.
For broker-dealers, these themes show up through the lens of Regulation Best Interest. The focus is on how firms handle conflicts, use complex and illiquid products, address dual-registration issues, choose account types, and craft Form CRS and other public-facing communications. The days of vague disclosures and generic explanations are over; regulators now expect granular, documented reasoning tied to specific clients and scenarios.
GiGCXOs helps firms respond to this reality with AICompliance360 and targeted Reg BI audits. We perform gap analyses of advisory processes, align actual practices with written standards, review fees, share classes, and compensation for conflicts that examiners will target, and conduct mock fiduciary and Reg BI exams that are based on real files rather than hypotheticals.
Private Credit and Complex Products: The New Hot Zone
Private credit and other alternatives are now squarely in the spotlight. The SEC is concerned about due diligence, valuation, liquidity, concentration risk, and whether investors genuinely understand the products recommended to them. If your platform includes private credit strategies, interval funds, complex ETFs, structured notes, or other non-plain-vanilla products, you should expect exam teams to ask for evidence of a clear due diligence framework, documented investment committee processes, and written rationales for product selection versus simpler or cheaper alternatives. They will also want to see that recommendations are tied to client objectives and risk profiles in a way that is traceable and defensible.
GiGCXOs supports firms by building and enhancing alternative product due diligence procedures and files, preparing product comparison and risk summary materials, and designing supervisory reviews that flag concentration, complexity, and liquidity concerns before regulators do.
Broker-Dealer Oversight: Financial Responsibility and Retail Practices
For broker-dealers, the SEC’s priorities emphasize financial responsibility, customer protection, operational resiliency, and retail sales practices. This includes scrutiny of net capital monitoring, customer asset protection, cash sweep arrangements and conflicts, prime brokerage activities, and recommendations involving complex or illiquid products for retail clients. Dual registrants and firms that straddle brokerage and advisory models will see deeper examination of account type recommendations, rollover advice, compensation differences between brokerage and advisory platforms, and the quality of documentation around why a specific recommendation was made.
GiGCXOs addresses these themes through AICompliance360 and supervisory control testing. We help broker-dealers build and test supervisory systems aligned with SEC and FINRA expectations, review cash sweep and revenue-sharing arrangements for conflicts, and prepare the documentation that exam teams are likely to request before they ask for it.
Cybersecurity, Data Privacy, and the New Reg S-P Reality
Cybersecurity remains a foundational exam priority. The SEC will examine how firms protect customer data, manage third-party risk, and respond to ransomware and other cyber incidents, now under the enhanced expectations created by the recent amendments to Regulation S-P. Firms will be expected to present a documented incident response framework that identifies roles, timelines, escalation paths, and notification triggers. Examiners will ask to see evidence of testing, tabletop exercises, and follow-up adjustments, as well as vendor management and data mapping that accurately reflect where customer information is stored and how it flows through your systems.
GiGCXOs helps firms meet these expectations by performing cyber and privacy gap analyses against the new Reg S-P amendments, drafting and updating incident response plans and playbooks, and embedding cyber and privacy tasks into your compliance calendar and testing program so that they are part of the firm’s ongoing operations and not just a binder on a shelf.
Fintech, Algorithms, and AI: Governance Over Hype
The SEC is also focusing on emerging financial technology, including automated tools, trading algorithms, and AI-driven solutions. Examiners want to know whether your descriptions to investors match reality and whether you have meaningful governance around how these tools are built, validated, monitored, and overseen by humans. At the same time, digital assets are now being treated as one dimension of emerging technology, not as an isolated category, which means the regulatory expectation is to integrate digital asset risk into your broader governance and disclosure framework.
GiGCXOs designed AICompliance360 to address this governance challenge. We help firms create AI and algorithm governance frameworks that include policies, model inventories, testing and validation documentation, and supervisory controls. We also review marketing claims about AI, smart order routing, or robo-advice to ensure they are supportable and compliant with SEC and FINRA advertising standards, rather than aspirational or misleading.
AML, Private Markets, and “Never-Examined” Firms
Anti-money laundering continues to be a core exam topic, but the focus is increasingly on whether programs are genuinely risk-based and tailored to the firm’s products, customers, and geographies. Private markets and newly registered or never-examined firms are seen as higher risk, and regulators will look closely at customer identification, enhanced due diligence, and suspicious activity monitoring and reporting in these environments.
GiGCXOs supports firms through AICompliance360, building or refreshing AML programs that reflect actual business risks, serving as independent AML testers and documenting results in exam-ready reports, and helping new or never-examined firms design sustainable compliance infrastructures rather than patchwork solutions.
Turning 2026 Exam Priorities into Your Compliance Roadmap
The SEC’s 2026 exam priorities are not meant as a surprise attack; they are a clear signal of where examiners are going. Firms that wait for an exam letter before acting will find themselves scrambling, while those that use these priorities as a roadmap can move into exam season with confidence.
GiGCXOs works with broker-dealers and RIAs to translate the SEC’s 2026 focus areas into a proactive plan. We perform risk assessments keyed to fiduciary duty, private credit and complex products, fintech and AI, cyber, and AML. We help firms build an exam binder of documentation that answers the first wave of questions before they arrive. We run mock exams that mirror how SEC and FINRA staff actually conduct reviews. And we implement tech-enabled oversight using the AICompliance360 compliance toolkit.
If you want to stress-test your firm against the SEC’s 2026 exam priorities, or you are a newly registered or never-examined firm looking to avoid painful lessons during your first review, GiGCXOs can help you become exam-ready long before the Division of Examinations appears at your doorstep.
