SEC Announces 2027 Examination Priorities: What Whistleblowers Should Know
On October 23, 2026, the Securities and Exchange Commission (SEC) released its Fiscal Year 2027 Examination Priorities, outlining the areas of heightened regulatory scrutiny for the coming year. The annual report, issued by the SEC’s Division of Examinations (“the Division”), identifies potential risks to investors and market integrity across investment advisers, broker-dealers, investment companies, and other market participants.
While the report does not announce any new whistleblower rewards, protections, or enforcement actions, it provides valuable insight into the types of misconduct the SEC intends to scrutinize.
Conflicts of Interest and Investment Adviser Misconduct
A central focus of the SEC’s 2027 examination program is whether investment advisers are fulfilling their fiduciary obligations, particularly when serving retail investors, older Americans, and individuals saving for retirement.
The SEC will prioritize examinations of advisers’ economic conflicts of interest, including fee arrangements, expense calculations, cash management practices, and other financial incentives that could compromise the impartiality of investment advice.
Examiners will also scrutinize whether advisers adequately disclose material conflicts, conduct appropriate due diligence, and recommend investments consistent with their clients’ financial objectives and risk tolerance.
The report places particular emphasis on complex and illiquid investments, including private credit, private equity, and certain exchange-traded funds (ETFs). Examinations of private fund advisers will also assess the accuracy of fee calculations, disclosures concerning investment risks, and the use of affiliated service providers.
For potential whistleblowers, these priorities highlight the importance of information concerning undisclosed conflicts of interest, misleading disclosures, improper fee practices, or investment recommendations that prioritize financial incentives over clients’ interests.
Investor Protection and Broker-Dealer Compliance
The SEC will also continue examining broker-dealers’ compliance with Regulation Best Interest (Reg BI), which establishes standards governing recommendations made to retail customers.
Examinations will focus on whether firms appropriately identify and mitigate conflicts of interest, consider reasonably available investment alternatives, and disclose relevant costs and risks.
The Division will pay particular attention to recommendations involving higher-risk products, including structured investments, private placements, illiquid assets, and products with complex fee structures. Recommendations involving older and otherwise vulnerable investors will also receive heightened scrutiny.
Beyond retail sales practices, the SEC will examine broker-dealers’ anti-money laundering (AML) programs, including suspicious activity reporting, customer due diligence, and risks associated with foreign financial institutions.
Notably, the report identifies potential market manipulation involving foreign-based companies, including “pump-and-dump” schemes, as an examination focus coordinated with the SEC’s Cross-Border Task Force.
These priorities may be especially relevant to individuals with knowledge of unsuitable investment recommendations, concealed financial incentives, suspicious trading activity, or deficiencies in firms’ AML compliance programs.
Emerging Technologies and Cybersecurity Risks
The SEC’s 2027 priorities also reflect growing concerns about emerging technologies and their implications for investor protection.
The Division will examine registrants’ use of advanced technologies, including what the report calls “super intelligence” (SI), in investment analysis, trading, compliance monitoring, and fraud detection.
Examiners will assess whether firms’ representations about their automated investment tools and algorithms are accurate, whether their operations align with investor disclosures, and whether algorithm-generated recommendations remain consistent with clients’ investment profiles.
The report also identifies cybersecurity threats involving SI-generated phishing messages, deepfake audio and video, identity theft, and unauthorized access to customer information.
For whistleblowers working in financial technology or cybersecurity, these examination priorities may be particularly relevant where internal information reveals misleading representations about automated systems, inadequate safeguards, or failures to address known risks.
What Does This Mean for SEC Whistleblowers?
The SEC’s existing Whistleblower Program, established under the Dodd-Frank Act, continues to offer eligible individuals monetary awards ranging from 10% to 30% of the sanctions collected in qualifying enforcement actions involving more than $1 million in ordered sanctions.
The program also provides confidentiality protections and prohibits certain forms of retaliation against individuals who report securities violations. Whistleblowers may submit information anonymously through an attorney, subject to the program’s requirements.
Listen to our Fraud in America episode about the SEC Whistleblower Program to learn more.
