What Is in the SEC's New Exam Handbook?

In brief: On October 1, 2026, the SEC's Division of Examinations published The SEC Exam Handbook: A Practical Guide on Process and Engagement, replacing the older EXAMS Brochure. The handbook lays out, in plain terms, how the Division conducts examinations and what a registered firm should expect at each stage. For asset managers, advisers, and broker-dealers, it turns a process that often felt opaque into a documented roadmap.

The SEC Exam Handbook is a published guide, issued by the Division of Examinations on October 1, 2026, that explains the examination process from first contact to close and sets out what registered firms can expect at each stage. It replaces the Division's previous EXAMS Brochure and, in the Division's words, offers "more insight and detail about what to expect during an examination." For institutions that hold securities registrations, it is the clearest statement yet of how an exam actually runs.

Why did the SEC publish a new exam handbook now?

The Division framed the handbook around transparency and consistency. According to the SEC's announcement, the document "provides a clear roadmap of the process used by division examiners across the country to help ensure consistency" and reflects a commitment to approach each examination "with an accessible and collaborative mindset."

SEC Chairman Paul S. Atkins tied the release to the agency's core mandate. "The Division's new handbook clarifies the examination process, offering regulated entities greater insight into what to expect during an exam and establishing clear expectations," Atkins said in the announcement, adding that the added transparency would "make examinations more effective."

The timing was signaled in advance. Speaking at the Investment Company Institute's Compliance, Risk, and Legal Conference in Nashville on September 16, 2026, Division Director Keith Cassidy previewed the handbook, describing it as "a modern and expanded replacement to our previous EXAMS Brochure" that would be "clearer, more practical, and built around the questions we hear most often from our registrants." On publication, Cassidy added that the Division's goal of being more accessible "provides registrants and the Commission with a more efficient and effective examination program."

Who does the Division of Examinations examine?

The Division runs the SEC's National Exam Program, and its reach is broad. It examines SEC-registered investment advisers, investment companies such as mutual funds and exchange-traded funds, broker-dealers, transfer agents, municipal advisors, securities-based swap dealers, clearing agencies, and self-regulatory organizations. The Division is staffed by more than 1,100 people working out of Washington and eleven regional offices, a scale reported by Holland & Knight in its coverage of the program.

Formed in 1995, the Division marked its thirtieth year in 2025. Its stated mission, set out on the SEC's own pages, is to protect investors, ensure market integrity, and support responsible capital formation. The findings from its exams feed directly into rulemaking, risk monitoring, and, where warranted, referrals to the Division of Enforcement. That last point matters: an examination is not an enforcement action, but it can become the trigger for one.

How does an SEC examination actually work?

This is the question the handbook exists to answer, and it is the one institutions ask most. An examination is a structured review of a firm's books, records, and practices to test compliance with the federal securities laws. Firm selection is risk-based rather than random, meaning the Division targets practices, products, and services it judges to present heightened risk to investors or to market integrity.

The handbook organizes the engagement into recognizable stages. In practice, an exam moves from notification and an initial document request, through staff review and on-site or remote fieldwork, to communication of findings and a closing. Cassidy described the document at the Nashville conference, per reporting of the speech, as "designed to align expectations and create predictability" and "filled with helpful resources for registrants to consult before and during their exams." The practical value for a compliance team is that the sequence, and the firm's obligations at each point, are now written down rather than inferred from experience.

The handbook does not change the law, and it does not expand the Division's authority. What it changes is the information asymmetry. A first-time registrant and a seasoned multi-strategy manager now work from the same published description of the process.

How does the handbook fit with the 2026 exam priorities?

The handbook is the "how," while the annual examination priorities are the "what." Each autumn the Division publishes its priorities for the coming fiscal year, signaling the areas it intends to scrutinize. The 2026 priorities, announced in November 2025, continued the Division's focus on fiduciary duty, standards of conduct, and risk areas spanning advisers, broker-dealers, and other registrants. Firms should read the two documents together.

Treading the process guide alongside the priorities lets a firm prepare on two fronts at once: knowing how the Division will engage, and knowing what it is likely to ask about.

What should institutions do with it?

The straightforward answer is to treat the handbook as a baseline for examination readiness. A firm that maps its own books, records, and controls against the stages the handbook describes can close gaps before a notification arrives rather than after. Because the Division's findings can inform policy and, where appropriate, enforcement referrals, the cost of being unprepared is not purely administrative.

The deeper point is cultural. An examination tests whether a firm's records are complete, consistent, and capable of being produced on request. Institutions that treat their records as programmable and auditable by design, rather than reconstructing them under deadline pressure, are the ones that handle an exam as routine. That is the posture the handbook rewards, and it is the posture Issuant is built to support for firms whose assets and records need to be verifiable on demand.

Frequently asked questions

Is the SEC Exam Handbook legally binding on firms?

No. The handbook is a descriptive guide to the examination process, not a rule or regulation. It does not create new obligations or expand the Division's authority. Firms' legal duties continue to flow from the federal securities laws and existing SEC rules. The handbook's purpose is to make the existing process transparent and predictable.

Does an SEC examination mean my firm is suspected of wrongdoing?

Not necessarily. The Division selects firms on a risk basis, and examinations are a routine part of oversight that serve to improve compliance, monitor risk, and inform policy. An exam is distinct from an enforcement action. That said, where staff identify serious issues, the Division can refer a matter to the SEC's Division of Enforcement, so firms should take the process seriously.

How does the handbook differ from the old EXAMS Brochure?

The handbook replaces and expands upon the previous brochure. Per the SEC, it offers more detail and insight into what to expect, and Director Keith Cassidy described it as a "modern and expanded" version built around the questions registrants ask most often. In short, it is longer, more practical, and more explicitly organized around the stages of an actual examination.