In a break from prior practice, the U.S. Securities and Exchange Commission’s (SEC) Division of Examinations (EXAMs) has published its priorities at the start of the 2024 fiscal year. It is a strong signal that the EXAMs staff expects asset managers to be well prepared to demonstrate their compliance with respect to “the key risks, trends, and examination topics” identified by the staff.

The EXAMs staff has grown substantially over the past year, and the increased “field presence” supports the stated goal of promoting transparency and compliance. This heavier examination hand comes in a period of ever-growing compliance burdens as the SEC has proposed, and recently adopted, rulemaking that stands to significantly affect the asset management industry.