SEC Publishes Draft Strategic Plan for Public Comment

The SEC recently published its Draft Strategic Plan for Fiscal Years 2026 through 2030. Although the plan does not create new compliance obligations, it provides useful insight into the SEC’s policy direction and the areas SEC-registered investment advisers may want to keep in mind as they prepare for annual review season.

The plan emphasizes the SEC’s core mission of investor protection, fair and efficient markets, and capital formation. For investment advisers, that means the basics still matter. Fiduciary duty, conflicts of interest, disclosure accuracy, fees and billing, marketing, custody, books and records, and the effectiveness of the compliance program remain central areas of review.

One of the more significant themes in the Draft Strategic Plan is digital assets and distributed ledger technology. The SEC discusses the need for a clearer regulatory foundation for digital assets, tokenized offerings, on-chain financial infrastructure, custody, trading, staking, and jurisdictional issues involving the SEC and CFTC. Advisers with exposure to crypto, tokenized assets, blockchain-related investments, digital asset strategies, or related platforms should continue to evaluate due diligence, custody, valuation, liquidity, risk disclosures, conflicts, client investment profiles, and books and records.

The plan also reflects continued interest in private markets and capital formation. Advisers that recommend, manage, or allocate to private funds, private credit, private placements, real assets, interval funds, or other alternative investments should continue reviewing due diligence, investor eligibility, valuation, liquidity, fees and expenses, conflicts, side letters or preferential terms, and whether disclosures match actual practices.

The SEC also discusses modernizing and simplifying disclosure practices and reviewing existing rules, including certain private fund reporting requirements, to determine whether they remain appropriate. This does not change current disclosure obligations. Advisers should continue to review Form ADV, Form CRS, client agreements, marketing materials, private fund disclosures, and other client communications for accuracy, consistency, and clear disclosure of material conflicts, fees, risks, services, limitations, and compensation arrangements.

Technology modernization is another important theme. The SEC discusses reviewing legacy systems, including EDGAR, improving data quality, using advanced analytics, and responsibly incorporating artificial intelligence and blockchain technologies. For advisers, this is a reminder to review AI use, technology vendors, cybersecurity, data protection, recordkeeping, supervision, vendor oversight, and controls over tools used for portfolio management, trading, client communications, marketing, research, and operations.

The Draft Strategic Plan also indicates that enforcement should focus on clear violations of established law, particularly fraud, deception, and manipulation, rather than on regulation-by-enforcement. Advisers should not interpret this as a reduced compliance standard. Core examination and enforcement risks under the Advisers Act remain relevant, including undisclosed conflicts, inaccurate disclosures, fee and billing issues, misleading marketing, custody deficiencies, books-and-records failures, and ineffective compliance policies and procedures.

The SEC is accepting public comments on the Draft Strategic Plan under File Number DSP-3. Comments are due no later than July 2, 2026. Compliance teams may want to review the Draft Strategic Plan as part of their broader annual review and regulatory monitoring process.

If you have questions about how these themes may apply to your firm’s compliance program or annual review, please contact Coulter Strategic Services.

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