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March 4, 2021

SEC Division of Examinations Announces 2021 Examination Priorities

In a press release dated March 3, 2021, the U.S. Securities and Exchange Commission’s Division of Examinations (the “Division”) announced its 2021 examination priorities. The priorities include greater focus on climate-related risks.

In particular, SEC Acting Chair Allison Herren Lee said, “This year, the Division is enhancing its focus on climate and ESG-related risks by examining proxy voting policies and practices to ensure voting aligns with investors’ best interests and expectations, as well as firms’ business continuity plans in light of intensifying physical risks associated with climate change. Through these and other efforts, we are integrating climate and ESG considerations into the agency’s broader regulatory framework.”

The following is an overview of the Division’s 2021 examination priorities as outlined in the announcement:
  • Retail Investors, Including Seniors and Those Saving for Retirement, Through Reg. BI and Fiduciary Duty Compliance
  • Information Security and Operational Resiliency
  • Financial Technology (Fintech) and Innovation, Including Digital Assets
  • Anti-Money Laundering Programs
  • The London Inter-Bank Offered Rate (LIBOR) Transition
  • Focus Areas Relating to Investment Advisers and Investment Companies
  • Compliance Programs
  • Registered Funds, Including Mutual Funds and ETFs
  • RIAs to Private Funds
  • Focus Areas Involving Broker-Dealers and Municipal Advisors
  • Market Infrastructure
  • Clearing Agencies
  • National Securities Exchanges
  • Regulation Systems Compliance and Integrity
  • Transfer Agents
  • FINRA and MSRB

As stated in their announcement, the published priorities for 2021 are not exhaustive and will not be the only areas the Division focuses on in its examinations, risk alerts, and outreach.


If you have any questions about this Alert, or any other regulatory matters, do not hesitate to reach out to Daniel Viola (Partner – Head of the Regulatory Group) at 212.573.8038 or via email at dviola@sadis.com or Eliott Frank (Partner) at 212.573.8148 or via email at efrank@sadis.com.