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Ext. Publication2026 SEC Exam Priorities: Private Funds and RIA Focus | Podcast
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What steps can private fund managers take to help keep their programs aligned with the SEC expectations? In this episode of Weaver: Beyond the Numbers, Sean Muller sits down with Michael Barakat to discuss the commission’s latest exam priorities and what they mean for investment advisers in the coming year.
Key Points:
- Focus on annual compliance reviews for newer private fund advisers
The SEC is paying close attention to advisers that are new to private funds or have recently transitioned from exempt status, ensuring they conduct thorough annual compliance reviews supported by strong policies and procedures. - Transparency in valuations and liquidity for private credit
With private credit strategies growing, examiners are looking for clear, consistent disclosures around valuation practices and liquidity management. They also expect marketing materials to accurately reflect capabilities, avoiding exaggerated claims about technology such as artificial intelligence. - Foundational practices remain a priority
While technology and new strategies evolve, the SEC continues to emphasize core principles like fee transparency, fair expense allocation and fair treatment of clients across different fund structures
Michael emphasizes that the annual priority list serves as a roadmap for firms before an examiner arrives. For established funds, this means tightening disclosures around fees and expenses, while newer entities should focus on building a program that can withstand regulatory review from day one. He notes that although certain trends, such as crypto, are absent this year, core expectations around cybersecurity and data protection remain high priority, especially as firms integrate more advanced technologies into their operations.
A central theme of the discussion is the unwavering nature of fiduciary duty, regardless of market shifts. As Michael explains, “Fiduciary responsibility means acting in your client’s best interest at all times — that’s the scope, that’s the spirit, and that’s where regulators will focus to ensure your program reflects that mindset.” This duty, which includes both a duty of care and a duty of loyalty, should guide every aspect of a firm’s compliance review from marketing materials to internal controls so that client interests remain the top priority.
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