Inayat Chaudhry

Inayat advises U.S. and cross-border issuers on public and private offerings, mergers and acquisitions, and ongoing SEC and exchange compliance, turning regulatory complexity into clear, executable strategy for founders, executives, and boards.

Inayat advises U.S. and cross-border issuers on a broad range of corporate and securities matters, including public and private capital markets transactions, mergers and acquisitions, and ongoing SEC and exchange compliance. She works closely with founders, executives, and boards to navigate the regulatory, disclosure, and governance milestones that accompany major capital markets events. She is energized by guiding clients through high-stakes transactions where clarity, responsiveness, and strategic judgment are critical.

The SEC’s Division of Examinations (the “Division”) recently announced its examination priorities (“Exam Priorities”) for fiscal year 2027.1 Although many of the Division’s core areas of focus remain consistent with fiscal year 2026, the 2027 Exam Priorities include notable changes and refinements, which we discuss below, along with other key 2027 examination priorities. Dorsey Observations Renewed focus on economic conflicts of interest. After certain economic-incentive topics received less emphasis in the 2026 Exam Priorities2, the Division has again expressly identified economic conflicts as an examination focus. The 2027 Exam Priorities indicate that the Division will prioritize reviewing advisers’ fiduciary obligations relating to economic conflicts of interest raised by fee rebates, fee and expense calculations, cash management, quid pro quo arrangements, and deposits and withdrawals. Greater emphasis on private-fund practices. Building on the private-fund items in the 2026 Exam Priorities, the 2027 Exam Priorities indicate that the Division will assess private-fund disclosures and controls relating to investment allocations, leverage, affiliated service providers, and fees and expenses. The Division also identified investments in private companies through special purpose vehicles (“SPVs”) and loans provided by private funds and business development companies (“BDCs”) as products the Division will scrutinize. Advisers, particularly private-fund advisers, should evaluate whether their disclosures and compliance programs address these areas. Expanded focus on AI-related cybersecurity risks. Wh