Published on Nov 11th, 2025 |

Turning SEC Exam Downtime into Opportunity | Chuck Martin Insights

Vigilant Insights

Introduction

As the government shutdown continues to stall regulatory operations, many Firms undergoing SEC Examinations have been left in an uncertain position.

With the Division of Examinations effectively paused, compliance teams are facing delayed timelines, restricted communication, and increased pressure to maintain readiness despite limited regulator engagement.

Vigilant’s Chief Operating Officer, Chuck Martin, MBA, shared his perspective in Ignites on the current shutdown and the opportunities it presents for Firms to review and improve their compliance programs.

Chuck Martin Insights

Chuck Martin Insights

Chuck noted that the current shutdown has created unexpected technical and operational complications for Firms mid-Exam. In one case, a client preparing to submit documents was instructed not to upload them due to the SEC’s secure transfer systems automatically deleting unopened files after 30 days, highlighting the nuanced challenges that can arise even from well-established compliance processes.

He emphasized that Firms should not view the regulatory pause as idle time. Instead, he encouraged compliance leaders to take advantage of this period to perform deeper reviews of their compliance frameworks, ensuring that documentation, procedures, and oversight practices remain strong and aligned with expectations once Examinations resume.

Vigilant's Conclusion

Vigilant’s Conclusion

Periods of regulatory disruption underscore the importance of preparation and adaptability.

At Vigilant, we see these moments as valuable opportunities for Firms to strengthen internal controls, revisit program documentation, and reinforce a culture of proactive compliance.

By using this downtime strategically, firms can emerge from regulatory pauses more organized, confident, and equipped to meet the SEC’s standards with precision and efficiency.

Learn more about how Vigilant can help in either performing a Mock Exam or On-Going Compliance Services.

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