SEC 2027 Exam Priorities: What Wealth Firms Should Do Now

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The short version

The SEC’s Division of Examinations released its Fiscal Year 2027 examination priorities on October 23, 2026. The message for wealth and asset managers is clear: examiners want proof that recommendations are in the client’s best interest, especially for retirement savers and older investors.

The priorities cover more than 34,000 registrants. They add new topics like tokenization and “super intelligence,” but the core of the agenda is familiar: fiduciary duty, conflicts of interest, Reg BI, and complex products. What has changed is the emphasis. Examiners are looking past written policies to whether firms actually do what they say.

Below is what that means in practice, and how to get your documentation exam-ready before an examiner asks.

1. Fiduciary duty: conflicts that touch the advice

For investment advisers, economic conflicts of interest lead the agenda. The Division will test whether financial incentives could compromise the impartiality of advice. Areas named include fee rebates, fee and expense calculations, cash management, and quid pro quo arrangements.

Examiners will also review four basics of the adviser relationship:

  • Disclosure: whether all material facts, including fee-related conflicts tied to account and product compensation, are fully and fairly disclosed.
  • Due diligence: whether the firm reasonably vetted the products and services it recommends.
  • Compliance program: whether policies are tailored to the firm’s operations, implemented, and tested for effectiveness.
  • Valuation: whether valuation processes and methods are reasonable.

This builds on a June 2026 risk alert describing conflicts advisers failed to disclose, or disclosed incompletely. The takeaway: a disclosure that exists is not enough if it does not match how the firm actually gets paid.

2. Reg BI: annuities top the complex-product list

For broker-dealers, Reg BI stays central. Reviews will cover product and account recommendations, conflict identification and mitigation, reasonably available alternatives, and the Care and Disclosure Obligations. Cost remains a key factor examiners expect to see weighed.

Variable annuities and registered index-linked annuities (RILAs) are first on the Division’s list of products of particular interest. Others include private placements, structured products, single-stock ETFs, 0DTE options, and ETFs holding private equity or private credit.

Examiners will also scrutinize recommendations that move a client into a substantially similar product. For annuities, that means exchanges and replacements will draw questions about what the client gains, what they give up, and what it costs.

Where PeerCompare Annuities helps: Showing a reasonably available alternatives analysis is far easier when you can benchmark a contract’s fees, features, and riders against comparable products. PeerCompare Annuities gives reps and supervisors that side-by-side view, with a documented record of what was considered.

3. Rollovers and retirement savers stay in the spotlight

Rollover and account-type recommendations are again named first in the Reg BI review areas. Examiners will look at recommendations to roll plan assets into an IRA or advisory account, and to open account types such as options, margin, or self-directed IRAs. Advice to retirement savers and older investors gets particular attention across both adviser and broker-dealer exams.

A rollover is often the single largest recommendation a client receives, and it usually carries a conflict: the firm earns more once assets leave the plan. Examiners will want to see that the client’s plan options, costs, and services were actually compared, not assumed.

Where RolloverAnalyzer helps: RolloverAnalyzer compares the client’s current plan against the proposed IRA or account on fees, investment options, and services. It produces a consistent, client-ready rationale and an audit trail supervisors can review, supporting Reg BI and PTE 2020-02 documentation.

Other areas to watch

  • Technology oversight: how firms monitor AI and advanced tools used in fraud detection, AML, Reg BI compliance, and trading.
  • Cybersecurity and Reg S-P: defenses against AI-driven phishing and deepfakes, plus readiness for the amended privacy rule.
  • Growing firms: advisers that grew through M&A, run dispersed branches, or added new clients, products, or services.
  • Never-examined advisers: especially recent registrants.

Your exam-readiness checklist

Use these questions to pressure-test your program before examiners do.

  • Conflicts: Does your Form ADV and Reg BI disclosure reflect every way the firm and its reps are paid, including product and account compensation?
  • Rollovers: Can you produce, for any rollover, a record comparing the plan’s costs and services with the recommended IRA or account? RolloverAnalyzer can standardize this across your reps.
  • Annuities: For each variable annuity, RILA, or exchange, is there evidence that reasonably available alternatives and costs were weighed? PeerCompare Annuities can supply the peer benchmark.
  • Account types: Is the rationale for advisory, options, margin, or self-directed IRA accounts documented at the point of recommendation?
  • Supervision: Do supervisors test whether conflict mitigation works, not just whether it exists?
  • Technology: Are AI and automated tools used in Reg BI or AML work inventoried and monitored?
  • Policies vs. practice: Would a sample of client files match what your written procedures say happens?

Documentation is your best defense

The FY2027 priorities do not create new rules. They tell firms where examiners will spend their time, and the answer is the moments that matter most to retirement savers: rollovers, annuities, and conflicted recommendations. Firms that can show a consistent, documented comparison at those moments will walk into exams with confidence.

InvestorCOM has helped wealth firms across North America turn disclosure and suitability requirements into a repeatable process. To see how RolloverAnalyzer and PeerCompare Annuities fit your exam preparation, contact our team.

This article is for general information only and is not legal or compliance advice.

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