SEC 2027 Exam Priorities: What AI Exams Mean for Marketing

October 28, 2026

Austin Carroll

On October 23, 2026, the SEC announced the Division of Examinations' Fiscal Year 2027 Examination Priorities. One word choice stands out. Last year's priorities referred to "artificial intelligence (AI)." This year's document uses "super intelligence (SI)."

The bigger change is where that technology shows up. The leadership letter describes "a sustained effort across the Division to integrate SI responsibly into examinations and risk assessment." The FY2026 priorities, released November 17, 2025, discussed how firms use AI. They did not describe the Division using it in its own examinations.

For marketing and compliance teams, the takeaway is direct. AI does not change the rules for your content, but it may make it faster for examiners to find where content breaks them. Below are three ways to protect your firm.

"The markets we oversee continue to evolve rapidly, and the examination program must evolve with them." Keith Cassidy, Director of the SEC's Division of Examinations

What Changed From the SEC's 2026 Exam Priorities

Three differences stand out between the two years.

The terminology changed. The FY2026 priorities referred to "artificial intelligence (AI)." The FY2027 priorities use "super intelligence (SI)."
The Division is now using the technology itself. The FY2026 priorities did not describe the Division using AI in its own examinations. The FY2027 priorities describe an effort to "integrate SI responsibly into examinations and risk assessment."
Scrutiny of firm technology claims continues. In FY2026, the Division said it would "review for accuracy registrant representations regarding their AI capabilities." In FY2027, it will assess whether "representations are fair and accurate."

The focus on firm claims carries over. What is new is that examiners plan to bring the technology to the review itself.

How the SEC Plans to Use AI in 2027 Examinations

The Division says its integration of SI is aimed at "augmenting staff capacity, enhancing oversight, and supporting mission-critical work without displacing examiner judgment." Its modernization initiative includes "increasing automation, reducing manual and duplicative steps," and identifying where SI-supported tools may "detect patterns and risks across complex datasets."

The letter also acknowledges that firms are "using generative SI tools to support research, drafting, coding, and client communications," and says the Division is assessing "whether firms continue to comply with existing, technology-neutral obligations." A missing disclosure is still missing whether a person or a model drafted the piece. What may change is how quickly it gets found.

How to Protect Your Firm When Examiners Use AI

If examiners can review more of your record, faster, the best defense is a complete record and knowing what is in it before they do.

1. Recordkeeping Has Never Been More Important

Recordkeeping is not a new obligation. Advisers must keep a copy of each advertisement under Advisers Act Rule 204-2, and broker-dealers must retain communications under FINRA Rule 2210 and Exchange Act Rule 17a-4.

What changes is how that record gets used. When examiners can analyze large datasets, gaps become easier to see: a missing version, an asset with no recorded approval, a social post nobody saved.

Warrant acts as a system of record for marketing, keeping every version, comment, approval, and publish date in an immutable audit log. A top global asset manager uses Warrant as the authorized recordkeeper for its FINRA marketing records.

2. Expect More Than Spot Checks

Traditional exam reviews sample. An examiner pulls a handful of pieces and tests them. Pattern-detection tools do not have to stop at a sample.

Consider a hypothetical. A fund updates its investment strategy and its prospectus, but 40 web pages, fact sheets, and advisor social posts still describe the old approach. An examiner sampling five pieces might miss the gap. A tool comparing all of them is far more likely to catch it.

The 2027 priorities name the comparisons examiners will make. Fund disclosures should "align with stated investment strategies, fund filings, and marketing materials." Claims about automated tools and algorithms should be "fair and accurate." Reg BI reviews cover "account and rollover recommendations," including those "made to older and vulnerable investors and those saving for retirement or college."

The practical answer is to review 100% of your own content before an examiner does. Warrant's AI Pre-Check scans every asset against 3,400+ tracked policies, plus your own disclosures and brand rules, before it reaches a human reviewer.

3. Start Monitoring What Is Already Live

Some regulators already monitor with technology. The UK Financial Conduct Authority says it uses "web scraping and social media tools that are able to detect, review and triage potential scam websites," and plans "to invest more into these technologies to proactively monitor markets."

In 2024, 19,766 financial promotions from authorised firms were amended or withdrawn, up from 10,008 in 2023. The FCA said "new technology also helped the FCA identify firms that did not meet its standards earlier and at scale." Much of that monitoring targets scams and unauthorised firms, but the direction is clear: regulators are watching live content, not only what firms hand over.

If you are not sure where your risk sits, start now. Warrant Monitoring crawls your full website, social accounts, and ads, checks them against the same policy library, and produces a report you can act on before an exam begins.

Why Banks, Credit Unions, and Insurers Should Pay Attention

The priorities apply to SEC registrants, but their reach extends beyond standalone advisers and broker-dealers. Many banks and credit unions offer investment services through affiliated or third-party broker-dealers and advisers, and that marketing falls within these exams.

Insurers that distribute variable annuities face the Reg BI focus directly, since "variable and registered index-linked annuities" are first on the list of products of particular interest. The Division also points to advisers that "have grown through mergers, acquisitions or other means, or are operating from multiple geographically dispersed branch offices," a description that fits many bank and credit union wealth programs.

What the SEC 2027 Exam Priorities Mean for Your Firm

The priorities represent the views of Division staff. The document states that it "is not a rule, regulation, or statement of the U.S. Securities and Exchange Commission," and that priorities "may shift in response to new or emerging risks, products and services, market events, or investor concerns."

The direction is still clear. Examiners are investing in tools that make inconsistency easier to find. Compliance can no longer be a final checkpoint. As examiners automate, the review process has to scale with them.

Not sure what is live on your website today? Get a full website scan from Warrant.

Frequently Asked Questions

What are the SEC's 2027 examination priorities? The Division of Examinations' FY2027 priorities cover investment advisers, investment companies, broker-dealers, self-regulatory organizations, clearing agencies, and other market participants, plus cross-cutting risks such as cybersecurity, emerging financial technology, Regulation S-P, Regulation S-ID, and Regulation SCI.

Will the SEC use AI in examinations? Yes. The Division plans to integrate SI into examinations and risk assessment, with tools "supplementing, but not replacing, staff judgment."

How do the 2027 exam priorities differ from 2026 on AI? The FY2026 priorities used the term "artificial intelligence (AI)" and focused on how firms use it. The FY2027 priorities use "super intelligence (SI)" and add the Division's own use of the technology in examinations and risk assessment.

Do the 2027 exam priorities mention marketing? Yes. Marketing is among the areas examiners review in adviser compliance programs, and fund examinations will compare disclosures against fund filings and marketing materials.

How can firms prepare for AI-assisted SEC exams? Keep a complete record of every marketing asset, version, and approval; review all of your content rather than a sample; and monitor what is already live on your website, social channels, and ads.

Sources: SEC press release, "SEC Announces Fiscal Year 2027 Examination Priorities" (Oct. 23, 2026); SEC Division of Examinations, Fiscal Year 2027 Examination Priorities (PDF); SEC press release, "SEC Division of Examinations Announces 2026 Priorities" (Nov. 17, 2025); SEC Division of Examinations, Fiscal Year 2026 Examination Priorities (PDF); FCA, AI Update (PDF); FCA, Financial promotions data 2024; FCA, "FCA closes 1,600 websites as it fights financial crime".