SEC Exams Director Announces New Examination Handbook and Outlines Registrant Expectations

Key Takeaways

• SEC Division of Examinations Director Keith Cassidy outlined efforts to make exams more accessible and integrated, including a new Examination Process Handbook to be published before the new fiscal year.
• The speech also sets out the Division's expectations for registrant conduct during exams.
• Compliance teams should use it to refine exam readiness and engagement practices.

Deep Dive

SEC Division of Examinations Director Keith Cassidy outlined efforts to make exams more accessible and integrated, including a new Examination Process Handbook to be published before the new fiscal year. The speech also sets out the Division's expectations for registrant conduct during exams. Compliance teams should use it to refine exam readiness and engagement practices.

Key developments include the following:
- A modern, expanded replacement for the prior EXAMS Brochure will be published later this month (September 2026), before the start of the new fiscal year. It will cover what to expect during an exam and steps to take if issues arise.
- The Division continues to publish annual priorities, aligned to the start of the fiscal year since 2023, along with risk alerts that include sample document requests and anonymized findings.
- Regional compliance outreach events are planned in Denver and Salt Lake City next month (October 2026), and the national IA/IC Compliance Outreach conference is scheduled for November 2026. Recent outreach covered the Regulation S-P amendments.
- Knowledge exchange sessions with the Divisions of Trading and Markets and Investment Management, a staff rotation program with policy groups, and consultation on novel issues are intended to improve consistency across geography and supervisory groups.
- Firms are encouraged to use the exit conference to challenge findings and supply overlooked policies or documents. Deficiency letters will generally not provide a remediation roadmap, because the SEC is not a merit regulator and firms must develop their own remedial measures.

Recommended actions for compliance professionals:
- Review the new handbook upon release and update exam-readiness playbooks accordingly.
- Review current annual priorities and risk alerts, and map them to existing controls.
- Prepare a firm overview covering business lines, risk areas, and compliance program, and identify who should attend the initial meetings.
- Establish protocols for document requests, such as requesting extensions or proposing rolling or partial production in good faith, and for notifying staff of unavailable interviewees.
- Prepare for exit conferences by assembling supporting policies and evidence to contest unwarranted findings.
- Register for upcoming outreach events, and escalate unprofessional exam conduct to the team lead, Assistant Director, or Division leadership as appropriate.

Risk implications are moderate and mainly operational. Firms with weak exam preparation, slow responses, or an adversarial posture may face longer exams and less favorable outcomes, while the absence of remediation guidance places the burden of designing corrective action on the firm. The speech also stresses that selection for an exam does not by itself signal wrongdoing, and that exams are risk-based and data-driven. Firms should still expect continued scrutiny of recently amended areas such as Regulation S-P.

Source: Securities and Exchange Commission