The Securities and Exchange Commission announced the Division of Examinations' Examination Priorities for Fiscal Year 2027 on 23 October 2026, in press release 2026-109. The priorities are a published supervisory statement rather than a rule, and they set out where the Division intends to direct examination resources in the 2027 fiscal year.
Examination Priorities: Fiscal Year 2027 uses the term super intelligence in place of artificial intelligence. Section VII.A.2, Emerging Financial Technology, states that registrants are increasingly using super intelligence in core business operations and systems, and that threat actors are using it to automate and accelerate cyberattacks. The Division will prioritise policies and procedures relating to monitoring super intelligence, and will assess whether algorithms lead to advice or recommendations consistent with investors' investment profiles or stated strategies. Section VII.A.3 addresses Regulation S-ID and Regulation S-P, and whether firms are updating those programmes to address emerging risks related to super intelligence and stolen credentials. Section VII.B, Regulation Systems Compliance and Integrity, names super intelligence and tokenisation of securities. Section V, Clearing Agencies, lists tokenisation alongside securities lending and operations as a high-risk area.
Investment advisers and broker-dealers that run super intelligence tools in advice generation, trade handling or client servicing should expect examiners to ask for the written policies governing model monitoring, and to test whether outputs match client investment profiles and stated strategies. Firms subject to Regulation S-ID and Regulation S-P will be asked how their identity theft prevention and privacy programmes were revised for super intelligence risks and stolen credentials. Clearing agencies, and entities within Regulation Systems Compliance and Integrity, face review of tokenisation of securities.
The priorities document carries no filing obligation and sets no deadline. It does not define super intelligence, and it leaves open how examiners will treat firms whose internal policies still use artificial intelligence as the operative term. The Division's leadership section also states that it will work to integrate super intelligence responsibly into examinations and risk assessment, so registrants may meet the technology on both sides of an examination.
Licentium advises crypto, AI and regulated financial services businesses on examination readiness and supervisory engagement in the United States, the United Kingdom and the European Union. Work we undertake includes mapping model governance records against published examination priorities, drafting monitoring policies for algorithmic advice tools, and preparing Regulation S-P and Regulation S-ID programme updates.