SEC Publishes New Examination Handbook
SEC Releases
Introduction
On October 1, 2026, the Securities and Exchange Commission’s (“SEC”) Division of Examinations (“EXAMS”) published a new SEC Exam Handbook. The Handbook replaces and expands upon the SEC’s previous examination brochure and is intended to provide Registrants with additional insight and detail regarding what to expect during an examination.
According to the SEC, the Handbook provides a clear roadmap of the examination process used by Division examiners across the country to help promote consistency. The SEC also stated that the Handbook is designed to emphasize an accessible and collaborative approach to examinations.
The Handbook addresses the examination process from start to finish, including what EXAMS expects from Registrants and what Registrants can expect from EXAMS. It also provides resources and avenues for Registrants to provide feedback or raise questions during the examination process.
Key Takeaways
- The Handbook provides a clearer roadmap of the SEC examination process.
- It outlines the process from candidate selection and exam announcement through information requests, interviews, the Exit Conference, Disposition Letter and, where applicable, a Registrant Response.
- Most examinations begin with the CCO or other regulatory contact.
- Staff generally begins with an introductory call, followed by a formal examination letter and initial information request. The Handbook also notes that keeping regulatory filings current and accurate can make examinations more efficient and reduce findings.
- The Handbook provides clearer expectations for document production.
- While records are generally expected to be available within 24 hours, staff typically provides two weeks for the initial production and may allow reasonable extensions or rolling productions where appropriate.
- Examinations may involve personnel, on-site visits and third parties.
- Staff may interview employees, visit the Registrant’s offices, and request information from service providers such as Custodians, Administrators and Auditors. For videoconferences, staff does not consent to recording, transcription or AI notetaking tools.
- EXAMS emphasizes active communication throughout the examination.
- Registrants are expected to provide knowledgeable personnel, respond promptly, maintain accurate filings, actively engage with staff and be transparent about relevant compliance issues.
- The Exit Conference and Disposition Letter are key parts of completing an examination.
- Staff typically discusses identified issues during an Exit Conference before issuing a Disposition Letter. The Handbook states that most examinations conclude with a deficiency letter requesting corrective action.
- The Handbook identifies key examination deadlines.
- A Disposition Letter is generally issued within 180 days, Registrants are typically given 30 days to respond to a deficiency letter, and staff strives to provide any further comments within 60 days of the response.
Vigilant’s Conclusion
The SEC’s new Exam Handbook provides Registrants with a more detailed and transparent roadmap of the examination process, from risk assessment and initial contact through information requests, interviews, the Exit Conference, and the final Disposition Letter. The SEC stated that the Handbook is intended to provide greater clarity, consistency, and predictability regarding what Registrants can expect during an examination.
The Handbook also establishes clearer expectations for both EXAMS and Registrants, including timely and organized document production, knowledgeable personnel, active communication with staff, accurate regulatory filings, and transparency regarding compliance issues relevant to the examination. It also provides specific timing expectations for Disposition Letters, responses to deficiency letters, and subsequent staff comments.
Importantly, the Handbook does not create new regulatory obligations or alter existing law. Rather, it provides additional guidance and practical insight into how EXAMS conducts examinations and how Registrants are expected to engage throughout the process.
If your firm is preparing for an SEC examination or looking to strengthen its examination readiness, schedule a call with Vigilant to learn more about our Mock Exam Services and how we can help support your firm throughout the examination process.