The SEC’s Division of Examinations announced a new handbook on 1 October to explain its examination process and engagement with regulated firms. The full document provides detail that the launch release alone does not: three time periods have different triggers and different degrees of certainty.[1][2]
The handbook’s timing provisions
| Stage | Period | Starting point and qualification |
|---|---|---|
| Disposition letter | 180 days | Later of on-site completion, if applicable, and receipt of all requested records; limited complex cases can receive an additional 180 daysSource 2 |
| Firm’s deficiency response | Typically 30 days | Date of the deficiency letter; request an extension promptly if neededSource 2 |
| Further staff comments | Target of 60 days | Firm’s response; staff may instead contact the firm about expected timingSource 2 |
What an examination outcome does and does not establish
A disposition can conclude the examination, conclude it without findings, or request corrective action. The handbook says a deficiency letter does not grade a firm or rank it against peers. Silence about an activity is not a conclusion that the activity complies with securities law, and closure does not prevent later Commission action.[2]
The guide also explains that urgent matters can be referred for enforcement without an exit conference or deficiency letter. A firm should therefore treat the ordinary process description as a guide to engagement, rather than a promise that every procedural step will precede a referral.[2]
Practical changes to preparation
The handbook tells participants that staff do not consent to recording, transcription or similar automated note-taking tools in meetings. It also identifies the examination hotline, 202-551-EXAM and [email protected], as a route for confirming staff identities and raising concerns.[2]
For an internal timetable, the most useful record is the actual trigger: completion of the on-site portion, acknowledgement of the final document delivery, the dated deficiency letter and the firm’s response. Labelling the examination’s opening date as the start of a universal 180-day completion deadline would give management the wrong expectation.
The handbook explains procedure under the existing framework. It is not a blanket exemption from recordkeeping or a new authorisation for a business activity. Its value is a clearer account of the process, the communications and the distinct clocks.
Sources & further reading
- SEC’s Division of Examinations Announces New Exam Handbook US Securities and Exchange Commission · 1 Oct 2026 · Accessed 27 Oct 2026
- The SEC Exam Handbook: A Practical Guide on Process and Engagement US Securities and Exchange Commission · Accessed 27 Oct 2026