Priorities Include Artificial Intelligence and Other Emerging Technologies, Complex Products, Reg BI, Cybersecurity, Outsourcing, Private Funds and Compliance with New and Amended SEC Rules

On October 21, 2024, the Division of Examinations (the “Division”) of the U.S. Securities and Exchange Commission (“SEC”) released its examination priorities for fiscal year 2025 (which started October 1, 2024). Over the course of 2025, the Division intends for its examinations to focus on the use of artificial intelligence and other emerging technologies (including digital engagement practices, complex products, cybersecurity, outsourcing, private fund advisers, and compliance with new and amended SEC rules, such as the recent amendments to Regulation S-P and SEC rule changes relating to the securities industry’s transition to a T+1 standard settlement cycle for most securities transactions.

In this Legal Update, we provide a brief overview of the Division’s 2025 priorities, with a focus on topics relevant to broker-dealers and investment advisers. Broker-dealers, investment advisers and other SEC registrants should review the priorities closely and evaluate their own compliance efforts and examination preparedness, including by raising awareness within their organizations and identifying and addressing opportunities to strengthen internal controls and compliance procedures.