The SEC’s 2026 Examination Priorities make clear that transparency, effective internal controls, and operational rigor are no longer optional for private fund managers and RIAs; they are foundational regulatory expectations.
As the private capital markets continue to scale, the SEC is sharpening its focus on how advisers run their operations, manage investor dollars, and uphold their fiduciary duty. The priorities for 2026 hit directly at the core of fund operations—valuation, expenses, conflicts, cybersecurity, and the quality of your compliance program.
The SEC is zeroing in on how fund managers identify, disclose, and mitigate conflicts of interest.
Expect a focus on:
Advisers managing private funds with illiquid, complex, or higher-cost strategies should anticipate a deeper review.
Examinations in 2026 will assess whether policies and procedures are reasonably designed, implemented, and periodically reviewed.
That includes:
For firms that have grown quickly or added new strategies should ensure that compliance considerations keep pace.
With private credit, NAV lending, and complex capital structures surging, valuation oversight is front and center.
Expect examiners to drill into:
Managers should prepare for detailed walkthroughs of valuation controls.
Operational resilience has become a regulatory expectation—not a best practice.
Here’s where SEC scrutiny is intensifying:
Expect examiners to focus on how firms govern and supervise outsourced services, not just the vendors’ responsibilities.
The Marketing Rule remains a focus, particularly on private funds using complex performance metrics.
Examiners will scrutinize:
If your firm uses third-party data, attribution models, or AI-enabled tools for performance, documentation will be key.
If you’re new to registration or have simply never been examined, you should be prepared for a new registrant exam. These exams often focus on:
Early-stage advisers or first-time managers should expect a full top-to-bottom review.
The SEC’s Division of Examinations emphasizes that examinations continue to be risk-based, with priorities informed by emerging market risks, technology shifts, evolving fund structures, and lessons from prior exams. These priorities reflect the SEC’s continued focus on private fund transparency, consistency of disclosures, investor protection, and operational robustness.
Petra was built by former fund CFOs, controllers, compliance leaders, and operators who have sat exactly where you sit today. We understand the realities of private fund operations because we lived them.
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