The SEC’s New Exam Handbook: What Registered Investment Advisers Should Know

A New Era of Transparency

On Oct. 1, 2026, the SEC’s Division of Examinations released The SEC Exam Handbook: A Practical Guide on Process and Engagement, replacing its prior examination brochure and providing registrants with a more detailed explanation of the examination process. While the handbook does not create new legal obligations for SEC registered investment advisers (RIAs), it offers meaningful insight into how examinations are selected, conducted, and concluded.

A key theme throughout the handbook is that examinations are not an indication of misconduct. Rather, they are a risk-based supervisory tool intended to promote compliance, monitor emerging risks, and protect investors. By providing greater transparency into its approach, the SEC seeks to improve communication and consistency between regulators and registrants.

The Examination Begins Before Notification

One of the handbook’s most important messages is that the examination process starts well before a firm receives a notification letter. According to the SEC, exam staff perform an initial risk assessment using information such as regulatory filings, prior examination results, investor complaints, referrals, and industry developments before deciding whether to open an examination.

For RIAs, this reinforces the need to view examination readiness as a continuous process. Form ADV disclosures, compliance policies, marketing materials, and required books and records should be maintained accurately and consistently at all times. Firms with strong day-to-day compliance practices may be better positioned when selected for review.

Managing Information Requests

Once an examination is initiated, advisers can expect requests for documents and information. The handbook offers greater clarity regarding how those requests are issued and managed and emphasizes the SEC’s expectation that firms respond promptly, completely, and accurately.

Delays, incomplete submissions, or inconsistent responses can unnecessarily prolong an examination and increase regulatory scrutiny. Advisers should therefore establish clear procedures for gathering documents, validating responses, and coordinating communications with SEC staff.

The handbook also notes that examiners may obtain information from third parties. As a result, it is important that information maintained by custodians, administrators, compliance consultants, and other service providers is consistent with records maintained by the adviser.

Interviews and Ongoing Dialogue

The handbook explains that examinations often involve interviews, on-site visits, and continuing discussions with personnel across the organization. SEC staff may meet with senior management, chief compliance officers, portfolio managers, operations personnel, and others responsible for key functions.

These discussions provide advisers with an opportunity to explain their business model, compliance framework, and internal controls. Examiners frequently assess whether a firm’s actual practices are consistent with its written policies and regulatory disclosures, making preparation and consistency particularly important.

The SEC also acknowledges that examinations are often iterative. Questions may evolve as information is reviewed, and firms should be prepared for ongoing dialogue throughout the process.

A More Collaborative Approach

A notable feature of the new handbook is its emphasis on professionalism and cooperation. Through a “Working Together” framework, the SEC outlines what registrants can expect from exam staff and what exam staff expect from registrants in return.

The handbook encourages respectful communication, transparency, and timely information sharing. Although examinations remain regulatory reviews, the SEC presents them as collaborative engagements intended to foster compliance, protect investors, and promote market integrity.

Understanding Examination Outcomes

The handbook also provides greater clarity around how examinations conclude. At the end of fieldwork, firms may participate in an exit conference during which examiners discuss preliminary observations. Outcomes may range from a clean closing letter to deficiency findings that require corrective action.

The SEC emphasizes the importance of responding thoughtfully to deficiency letters. Effective responses should clearly describe remediation measures and any enhancements made to the compliance program. Demonstrating a commitment to corrective action can influence how regulators view a firm’s compliance culture and may help reduce future regulatory risk.

Key Takeaway for RIAs

The central message of the SEC’s new handbook is that examination readiness should be embedded in everyday operations. Strong books and records, accurate disclosures, effective compliance policies, documented supervisory procedures, and a culture of responsiveness remain the foundation of a successful examination experience.

While the handbook does not change substantive compliance requirements, it provides RIAs with unprecedented visibility into the SEC examination process. Firms that use this guidance to evaluate and strengthen their compliance programs will be better prepared when the SEC ultimately initiates a review.

Disclaimer: This article was prepared by a CBIZ affiliate other than CBIZ Investment Advisory Services (CBIZ IAS) and does not necessarily reflect the views, guidance, or services of CBIZ IAS. This content is for informational purposes only and should not be considered investment advice or a recommendation from CBIZ IAS. Any investment decisions should be made only after consulting with a qualified investment advisor or financial professional.