As the financial services industry braces for heightened supervisory scrutiny, the SEC’s Division of Examinations (“the Division”) released its Fiscal Year 2026 Examination Priorities, a clear signal of where attention will be focused.  

Two themes stand out for retail facing firms: 

1. Retail sales practices of broker-dealers (especially around account, product and rollover recommendations) and compliance with Regulation Best Interest (“Reg BI”). 
2. Investment advisers’ adherence to fiduciary standards of care and loyalty when serving retail clients.  

 

Below we unpack each area and outline how InvestorCOM’s compliance and communications platform can help you build a stronger exam ready posture. 

1. Broker-Dealer Retail Sales Practice & Regulation Best Interest

The Division’s priorities make very clear that broker-dealers’ retail sales practices will be a significant focus under the 2026 exam cycle. They particularly highlight the following: 

• Recommendations of products, account types and rollovers (for example, moving from an employer plan account to an IRA or switching account type). Identification and mitigation of conflicts of interest in these recommendations (including dual registrant firms, variable compensation incentives, or limited product menus).  

• Processes for reviewing “reasonably available alternatives” when making recommendations.  

• The “Care Obligation” under Reg BI: i.e., consideration of a customer’s investment profile (time horizon, risk tolerance, liquidity needs, costs and exit options) and appropriate matching of product and account.  

• Specific scrutiny for: complex or tax advantaged products (e.g., variable annuities, structured products, illiquid ETFs), account type changes (e.g., margin, self directed IRAs, rollovers), older clients and retirement savings contexts.  

• Review of the broker-dealer’s relationship summary (Form CRS) for retail investors: the content of disclosures about services, fees and conflicts of interest.  

Why this matters:
Examiners will expect broker-dealers to show documented, repeatable processes – not ad hoc decision making – for retail recommendations. Firms should anticipate sample testing of rollovers, account type conversions, product swaps, limited product shelf recommendations and whether the firm is adequately supervising branch offices and registered representatives. 

How InvestorCOM helps: 

• The platform supports Form CRS production, disclosure and delivery (ensuring your relationship summary meets the expectations around clarity, completeness and delivery). https://investorcom.com/investorcom-launches-compliance-platform-regulation-best-interest

• Solutions such as PeerCompare™ and AccountCompare™ enable firms to document the “reasonably available alternatives” analysis for product and account recommendations. This helps show that the firm considered and compared options—not simply recommended one. 

• RolloverAnalyzer™ allows firms to document rollover recommendations: collect data, compare alternatives (costs, suitability, client profile), generate disclosures and maintain audit trail records.https://investorcom.com/prove-rollover-compliance-with-confidence/com 

• A centralized platform for oversight and documentation helps supervisors quickly pull together the supporting records examiners may request. 

If you’re a broker-dealer preparing for 2026 exam coverage, this combination of disclosure, comparison, documentation and supervisory oversight goes straight to the key items the SEC will look at. 

2. Investment Adviser Adherence to Fiduciary Standards of Conduct

For registered investment advisers (RIAs) and advisory arms, the Division’s priorities place continued emphasis on the core fiduciary obligations: duty of care and duty of loyalty. Key dimensions include: 

• A review of advisers’ financial conflicts of interest and whether those conflicts impair impartial advice.  

• Whether advisers consider the full range of relevant factors when recommending investments: cost, liquidity, risks, time horizon, exit options and the product’s appropriateness for the client’s profile.  

• Best execution obligations: the examination of whether advisers seek to maximize value for clients given their specific circumstances.  

• Elevated focus on: alternative investments, complex products, higher cost investments, products with illiquid underlying assets, and advisers serving older or retirement saving clients.  

• Particular attention on “dually registered” firms (i.e., advisers also registered as broker-dealers) and whether the adviser side is sufficiently insulated from sales oriented conflicts.  

• Examination of the adviser’s compliance program — its policies and procedures, enforcement, annual review of program effectiveness, and whether disclosures address fee related conflicts in a meaningful way. 

Why this matters:
Advisers will not only need to show that their recommendation process is robust, but also that they can defend why they selected a given investment over alternatives and that conflicts were managed or avoided. Examiners will likely pull specific client engagements (especially those involving retirement assets, illiquid products, or account conversions) and expect full documentation. 

How InvestorCOM helps: 

• While InvestorCOM is often referenced in the broker-dealer context, its framework of product shelf, account type comparison and disclosure supports firms that provide advisory services as well. The same disciplined approach to “reasonably available alternatives” and documentation applies.  

• By integrating KYC, product review and disclosure workflows, firms can meet the “duty of care” standard by showing that a client’s profile was collected, product alternatives were assessed and the recommended path documented. 

• On the “duty of loyalty” side, InvestorCOM’s digital documentation and audit trail helps firms show how conflicts were disclosed, mitigated and that the client’s interest came first. 

• The supervisory dashboards allow compliance teams to oversee adviser behavior, identify outlier trends (e.g., repeated recommendations of higher cost products) and thus demonstrate the robustness of the compliance program — a focus area in the 2026 exam priorities. 

 

Bringing It All Together: Exam Readiness Through Technology 

The SEC’s 2026 Examination Priorities send a clear message: firms must have processes, documented evidence, and effective supervision around retail facing recommendations, whether via a broker-dealer model or advisory model. Firms that rely solely on spreadsheets, manual documentation or ad hoc workflows are at risk of being unable to demonstrate compliance when examiners ask for detailed evidence. 

InvestorCOM’s platform offers a strategic compliance advantage by bringing together three critical capabilities: 

• Disclosure & client relationship documents (e.g., Form CRS for broker-dealers, disclosures for advisers) 

• Comparative analytics (product shelf, account type, rollovers) to support “reasonably available alternatives” and suitability/fiduciary decisions 

• Supervision & audit trail capabilities to evidence process consistency, identify exceptions and support retrospective review 

Firms that proactively adopt such a technology enabled approach are better positioned not only to respond to regulators’ questions, but to convert compliance into a differentiator: more efficient workflows, better advisor-client dialogue and stronger documentation. 

About InvestorCOM
InvestorCOM is a leading RegTech platform serving wealth managers and financial professionals, offering modules like AccountCompare™, PeerCompare™, RolloverAnalyzer™ and ComplianceExpress™. The platform is designed to support firms with the kinds of capabilities that align with the SEC’s expectations under the 2026 Examination Priorities.