In mid-November, the U.S. Securities and Exchange Commission (SEC) released its Fiscal Year 2026 examination priorities, reflecting areas that the Division anticipates will be of significant importance in the new year. This year’s report signaled a realignment of regulatory focus – one consistent with the SEC’s shift towards transparent, practical compliance. As outlined across Sections I, II, and VII, the Commission is emphasizing investor protection, the use of artificial intelligence (AI) and emerging technologies, cybersecurity and operational resiliency and core regulatory compliance obligations—including fiduciary duty, Regulation S-P, and the amended Names Rule—while notably stepping back from crypto-asset regulation as a primary focus area. The overarching message is a return to fundamentals, with increased attention on how firms operate, govern risk and sustain compliance over time.
For broker-dealers, these themes converge around a common takeaway: regulators are increasingly focused not just on outcomes, but on the systems, controls and governance that support them.
A Holistic Evaluation of Financial Responsibility
Within the 2026 priorities, Section III.A (Broker-Dealer Financial Responsibility Rules) underscores that compliance is being evaluated as an integrated control environment. Examinations will continue to assess compliance with the Net Capital Rule (Rule 15c3-1) and Customer Protection Rule (Rule 15c3-3), but with greater scrutiny on the internal processes, procedures and controls that hold up those obligations on an ongoing basis.
In practice, this includes how firms monitor capital and liquidity between filing periods, how exceptions are identified and escalated and whether regulatory filings are prepared using consistent, well-documented assumptions. As described in Section III.A, the timeliness and accuracy of financial notifications and required filings remain central to exam reviews. Late submissions, revisions or inconsistencies across reports are no longer viewed as administrative issues, but as indicators of potential control weaknesses.
Section III.A also highlights operational resiliency as a core component of financial responsibility, including the supervision of third-party and vendor-provided services that contribute to the records used in regulatory reporting. Reliance on external systems does not diminish a firm’s accountability for data integrity, change management and reconciliation processes. Examiners will further assess whether firms maintain sufficient liquidity to manage stress events, particularly where cash sweep programs, concentration risk or prime brokerage activity introduce added complexity.
Against this backdrop, the FinOp broker-dealer function plays a central role in exam readiness. Effective FinOp oversight helps ensure regulatory reports are prepared and filed with precision, financial notifications are timely and accurate and the underlying control framework can withstand regulatory scrutiny.
The SEC’s continued oversight of FINRA, outlined in Section IV.B of the 2026 Examination Priorities, reinforces these expectations. While directed at FINRA itself, this section signals continued alignment between SEC priorities and FINRA’s examination posture, particularly around financial responsibility, supervisory rigor and documentation standards. This is a clear indicator that expectations across regulators are converging, not diverging—making durable controls and defensible processes essential regardless of the examining authority.
The Role of FinOp Oversight in an Evolving Exam Environment
Taken together, the SEC’s 2026 examination priorities reflect a broader shift toward evaluating how firms operate, not just whether they comply. For broker-dealers, financial responsibility is no longer a periodic exercise tied to filing deadlines, but an ongoing discipline that underpins investor protection, operational resiliency and regulatory credibility. Firms that invest in strong governance, experienced FinOp oversight and disciplined reporting processes will be better positioned to navigate exams, audits and market stress with confidence.
ACI has supported broker-dealers for more than 40 years by providing experienced outsourced FinOp oversight and regulatory financial operations support designed to meet the practical demands of SEC and FINRA examinations. Our team of licensed Series 27/28 FinOps and CPAs partners closely with firms to help ensure accurate, timely regulatory reporting, effective net capital and customer reserve oversight and durable internal control frameworks.
ACI’s FinOp services are designed to support broker-dealers across the full lifecycle of financial responsibility obligations, including FinOp and Principal Officer support (Series 27/28, outsourced PFO, POO, and backup coverage), regulatory financial reporting and filings, regulatory bookkeeping and reconciliations, and specialized support for carrying and clearing firms facing heightened operational complexity. We also assist firms with internal control over compliance (ICOC) best practices, liquidity and stress testing frameworks, FINRA New Member Application support and preparation for regulatory examinations and PCAOB audits.
As regulatory expectations continue to converge around consistency, documentation and operational discipline, experienced FinOp support and services can play a critical role in helping firms meet their obligations while minimizing exam friction.
Broker-dealers seeking to strengthen their financial operations framework are encouraged to contact the ACI team to learn more about how our FinOp services can support their compliance and operational objectives.