The SEC Division of Examinations' Fiscal Year 2025 Priorities

WilmerHale
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On October 21, 2024, the Securities and Exchange Commission Division of Examinations published its examination priorities for fiscal year 2025.1 In this alert, we offer ten observations for broker-dealers. Our observations are not intended to be a comprehensive summary of the exam priorities, which are quite short and should be reviewed in their entirety. Instead, we offer some takeaways and suggestions for broker-dealers as they consider their compliance programs and prepare for examinations. Our observations relate to Regulation BI, Form CRS, bank sweep programs, the execution of retail orders, Regulation SHO, artificial intelligence, third-party vendors, spot crypto exchange-traded products, registrants with crypto operations, Regulation S-ID and Regulation S-P.

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