# SEC fiscal 2027 exam agenda targets adviser fees, cash management and AI URL: https://www.financialadvsr.com/article/sec-fiscal-2027-exam-agenda-targets-adviser-fees-cash-management-and-ec6fa7 Published: October 27, 2026 By: Theo Marsh, Regulation Correspondent Section: Regulation Publisher: Financial ADVSR (https://www.financialadvsr.com) The SEC Division of Examinations has published its fiscal 2027 priorities, with economic conflicts, illiquid products, acquisitive firms and AI oversight among the areas under review, according to InvestmentNews. InvestmentNews reported on Oct. 26 that the SEC's Division of Examinations has set out its examination priorities for fiscal year 2027, with adviser fees, cash management and mergers and acquisitions among the areas drawing attention. A WilmerHale client alert said the Division published the priorities on October 23, 2026. The full document, titled Fiscal Year 2027 Examination Priorities, is hosted on sec.gov, according to the SEC's own posting. Securities.io, which also covered the release, said the Division framed the document around heightened risks across more than 34,000 registrants and set out eight focus areas. Among them are the duties advisers owe their clients, conflicts, and new technologies. InvestmentNews reported that examiners will prioritize reviews of advisers' economic conflicts, with a particular focus on whether financial incentives could undermine the impartiality of their advice. InvestmentNews lists five places where conflicts can arise: rebates on fees, how fees and expenses are computed, the handling of cash, quid pro quo deals, and deposits and withdrawals. According to Securities.io, the conflict section refers back to a June 9, 2026 risk alert concerning disclosures that were missing, partial or deceptive. WilmerHale noted that this year's annual report describes economic conflicts with more particularity than before. On illiquid and complex products, InvestmentNews reported that examiners will look at whether a product suits a client's profile, weighing how easily it can be sold, how much its price swings, its expected returns, the investor's time frame, and what it costs to get out. Other products singled out are loan vehicles tied to private funds or BDCs, funds that use options strategies, inverse and single-stock exchange-traded funds, and ETFs holding assets that trade less freely. AdvisorHub reported separately that examiners will maintain a focus on acquisitive RIAs and on firms operating from geographically scattered branch offices. InvestmentNews's headline also points to M&A as a target, but the reporting reviewed for this article does not give further detail on how examiners will approach acquisitive firms or branch networks. On technology, InvestmentNews reported that examiners will look at firms' internal oversight of their AI use across fraud detection, back-office operations, anti-money laundering and Regulation Best Interest compliance, and trading. Where firms use automated advice tools, examiners will test whether the marketing claims made about them hold up and whether the algorithms produce results consistent with client profiles. Examiners will additionally look at firms' readiness for AI-generated phishing attempts and deepfaked voice and video impersonation. InvestmentNews's summary notes that super intelligence has entered the agenda, and Securities.io lists emerging technologies, including super intelligence, among the release's areas. WilmerHale said the 2027 priorities mostly carry forward the main fiscal 2026 topics, including fiduciary duties owed by advisers, Regulation Best Interest and cyber risk, now applied to newer offerings and business practices. According to Shulman Rogers, the fiscal 2026 priorities were released on November 17, slightly delayed by a federal government shutdown, and were the first list issued under SEC chair Paul Atkins. InvestmentNews reported that this year's publication landed just over three weeks ahead of last year's on the calendar. Shulman Rogers also said the SEC generally endeavors to examine around 15% of the total RIA population each year. Separately, Legal 500 has outlined the compliance timing for the amended Regulation S-P. Large covered institutions, including RIAs with $1.5 billion or more in assets under management, faced a December 3, 2025 deadline, while small covered institutions, including RIAs below that threshold, faced a June 3, 2026 deadline. Those are asset thresholds, not prices. According to King & Spalding, the June 2026 risk alert does not establish new legal obligations but signals the Division's ongoing examination priorities. Key facts: - The SEC Division of Examinations published its fiscal 2027 examination priorities on October 23, 2026, according to WilmerHale. - The release identifies eight key areas and covers risks across more than 34,000 registrants, according to Securities.io. - Examiners will review firms' monitoring of their own AI use in fraud detection, back-office work, AML and Reg BI compliance, and trading, according to InvestmentNews. - Under amended Reg S-P, the large-institution deadline was December 3, 2025 for RIAs with $1.5 billion or more in AUM, and the small-institution deadline was June 3, 2026, according to Legal 500. - The Division's June 9, 2026 risk alert on undisclosed, incomplete or misleading conflict disclosures is cited in the 2027 priorities, according to Securities.io. Why it matters: For advisors, the priorities signal where examiners are likely to focus during reviews, particularly fee structures, cash management arrangements and whether complex or illiquid products suit client profiles. Team leaders weighing a move and firm executives reviewing their disclosures and AI governance will find the emphasis on conflict disclosure and firm-level AI oversight directly relevant to their compliance planning. Sources: - InvestmentNews: https://www.investmentnews.com/goria/compliance/sec-2027-exam-priorities-target-ria-fees-cash-management-and-ma/268748 - AdvisorHub: https://www.advisorhub.com/sec-exam-priorities-target-advisor-fee-conflicts-illiquid-products/ - wilmerhale.com: https://www.wilmerhale.com/en/insights/client-alerts/20261026-sec-2027-exam-priorities-familiar-priorities-evolving-markets - sec.gov: https://www.sec.gov/files/2027-exam-priorities.pdf - investmentnews.com: https://www.investmentnews.com/regulation-legal-compliance/secs-2027-exam-priorities-put-ria-conflicts-and-cyber-risks-in-focus/268722 - securities.io: https://www.securities.io/sec-division-of-examinations-publishes-fiscal-2027-priorities/ - shulmanrogers.com: https://www.shulmanrogers.com/legal-alert-sec-releases-fy-2026-examinations-priorities-for-rias-and-others/