# Division of Examinations FY2025 Priorities: Examination Priorities: Fiscal Year 2025 — Division of Examinations Source: https://www.bankingnewsai.com/ai-regulation/documents/sec-exam-priorities-fy2025 Last updated: Aug 26, 2026 Released October 21, 2024, the FY2025 Examination Priorities named artificial intelligence a headline risk area alongside fiduciary duty, standards of conduct, and cybersecurity. Examiners were told to review registrant representations about AI capabilities for accuracy, assess whether firms have policies to monitor and supervise AI used in fraud prevention and detection, back-office operations, anti-money laundering, and trading, and examine how firms protect client records from loss or misuse through third-party AI models and tools. ## At a glance | Field | Value | | --- | --- | | Authority | [SEC](https://www.bankingnewsai.com/ai-regulation/sec) | | Type | Report | | Status | Superseded | | Published | Oct 21, 2024 | | Applies to | SEC-registered investment advisers, broker-dealers, funds, and other registrants, including bank-affiliated firms | | Official text | https://www.sec.gov/files/2025-exam-priorities.pdf | ## Key points - Four-part test for digital engagement practices and automated advice: representations fair and accurate; operations and controls consistent with disclosures; algorithms produce advice consistent with investor profiles; controls confirm regulatory obligations are met, including for older investors. - Explicit list of AI functions to be supervised: fraud prevention and detection, back-office, AML, and trading. - First priorities document to flag data-leakage risk from third-party AI models and tools. - Noted that some registrants are developing generative-AI applications and integrating AI into portfolio management and valuation. - Reviews also cover 'regtech' used to automate internal compliance processes. ## What changed for banks FY2025 was the first year the SEC's exam program treated AI as a standalone focus rather than a subset of cybersecurity. Bank-owned advisers and broker-dealers began receiving document requests for AI inventories, AI policies, and substantiation of AI marketing claims. ## Use cases it governs - [AI governance (general)](https://www.bankingnewsai.com/ai-regulation/by-use-case#governance-general) - [AML / KYC](https://www.bankingnewsai.com/ai-regulation/by-use-case#aml-kyc) - [Fraud detection](https://www.bankingnewsai.com/ai-regulation/by-use-case#fraud) - [Trading & capital markets](https://www.bankingnewsai.com/ai-regulation/by-use-case#trading-markets) - [Third-party & vendor AI](https://www.bankingnewsai.com/ai-regulation/by-use-case#third-party-vendors) - [Data & privacy](https://www.bankingnewsai.com/ai-regulation/by-use-case#data-privacy) > Superseded by [Division of Examinations FY2026 Priorities](https://www.bankingnewsai.com/ai-regulation/documents/sec-exam-priorities-fy2026). ## FAQ ### What AI uses did the SEC say it would examine in FY2025? AI used for fraud prevention and detection, back-office operations, anti-money laundering, and trading, plus the accuracy of any representations about AI capabilities and the protection of client data used with third-party AI tools. ### Is the FY2025 priorities document still current? No; it was superseded by the FY2026 priorities released November 17, 2025, which carry the AI section forward with minor changes. ## Related documents - [Division of Examinations FY2026 Priorities](https://www.bankingnewsai.com/ai-regulation/documents/sec-exam-priorities-fy2026) — Examination Priorities: Fiscal Year 2026 — Division of Examinations (Nov 17, 2025) - [Atkins remarks at Investor Advisory Committee (Sep 2026)](https://www.bankingnewsai.com/ai-regulation/documents/sec-atkins-iac-ai-disclosure-remarks-2026-09) — Remarks at the SEC Investor Advisory Committee Meeting on AI Technologies and the Public Markets Information Ecosystem (Sep 10, 2026) - [Atkins remarks at FSOC AI roundtable (Mar 2026)](https://www.bankingnewsai.com/ai-regulation/documents/sec-atkins-fsoc-ai-roundtable-2026) — Remarks at Financial Stability Oversight Council Artificial Intelligence Innovation Series Roundtable on Strategy and Governance Principles (Mar 4, 2026) - [Investor Advisory Committee AI disclosure recommendation](https://www.bankingnewsai.com/ai-regulation/documents/sec-iac-ai-disclosure-recommendation-2025) — Recommendation of the SEC Investor Advisory Committee Regarding the Disclosure of Artificial Intelligence's Impact on Operations (Dec 4, 2025) - [SEC withdrawal of proposed rules (33-11377)](https://www.bankingnewsai.com/ai-regulation/documents/sec-pda-proposal-withdrawal-33-11377) — Withdrawal of Proposed Regulatory Actions — including the predictive data analytics conflicts proposal (Jun 12, 2025) - [SEC v. Saniger (Nate, Inc.)](https://www.bankingnewsai.com/ai-regulation/documents/sec-nate-saniger-ai-washing-2025) — SEC Charges Founder of Nate, Inc. with Fraud Over False Claims About the Company's Use of Artificial Intelligence (Apr 9, 2025) - [Presto Automation AI-washing order](https://www.bankingnewsai.com/ai-regulation/documents/sec-presto-automation-ai-washing-2025) — SEC Charges Restaurant-Technology Company Presto Automation for Misleading Statements About AI Product (Jan 14, 2025) - [Delphia / Global Predictions AI-washing settlements](https://www.bankingnewsai.com/ai-regulation/documents/sec-delphia-global-predictions-ai-washing-2024) — SEC Charges Two Investment Advisers with Making False and Misleading Statements About Their Use of Artificial Intelligence (Mar 18, 2024) Last reviewed Aug 26, 2026. Cite the official text (https://www.sec.gov/files/2025-exam-priorities.pdf) for the rule and this page for the summary and dates. --- Canonical page: https://www.bankingnewsai.com/ai-regulation/documents/sec-exam-priorities-fy2025 Part of [BankingNewsAI](https://www.bankingnewsai.com/) — a free daily brief on AI in banking, an AI regulation tracker (41 authorities, 237 documents) and AI-strategy profiles of the 120 largest US banks. Markdown versions of every reference page: append `.md` to the page URL; index at https://www.bankingnewsai.com/llms.txt.