Regulatory Risk

The SEC Sets Out What It Wants to Examine in Super Intelligence and Automated Investment Advice

On October 23, 2026, the SEC’s Division of Examinations published its examination priorities for fiscal year 2027, naming super intelligence and automated investment advice among the risks it will examine across more than 34,000 registrants.

Assessments in examinations of automated investment advice, the priorities document states, “generally will include whether”:

  • “representations are fair and accurate;”

  • “operations and controls are consistent with disclosures made to investors;” and

  • “algorithms lead to advice or recommendations consistent with investors’ investment profiles or stated strategies.”

Those three questions connect what a firm promises, what it does, and what its customers receive.

Who the SEC Will Prioritize

The Division “remains focused on registrants’ use of certain products and services, such as automated investment tools and trading algorithms or platforms, and the risks associated with the use of emerging technologies and alternative data sources.” It says it “will prioritize firms that engage in activities such as automated investment advisory services, recommendations, and related tools and methods.”

The Division will also prioritize examinations of policies and procedures for monitoring SI, “including its use in fraud prevention and detection, back-office operations, compliance with AML and Reg BI obligations, and trading functions.”

Examiners will also review preparation for SI-powered cyber attacks. The Division writes that “threat actors are using SI to automate and accelerate cyberattacks,” naming SI-generated “phishing messaging and synthetic or deepfake voice and video used for social engineering.” Identity Theft Prevention Programs under Regulation S-ID are expected to address “emerging risks, such as those related to SI and stolen credentials.”

This post is for general informational purposes only and does not constitute legal advice. For questions about examination readiness for automated investment advice and the records that support it, consult qualified counsel or compliance professionals.

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