SEC Exam Plan Says ‘Super Intelligence’ Where 2026 Said ‘AI’

The Securities and Exchange Commission’s Division of Examinations published its fiscal year 2027 examination priorities on 23 October 2026, and the document uses “super intelligence (SI)” where last year’s edition said “artificial intelligence (AI)”. By our count of the text, the FY 2027 document uses ‘SI’ 11 times and ‘AI’ not at all; the FY 2026 document used ‘AI’ seven times and never used ‘super intelligence’.

Examination priorities are the SEC staff’s yearly list of areas of heightened focus; the release says they span the Division’s “more than 34,000 registrants”, from investment advisers to broker-dealers. The document carries a staff disclaimer: it is not a rule and creates no new obligations.

What Examiners Will Check

In its introduction, the document says plainly: “Registrants are increasingly incorporating super intelligence (SI) into their businesses.” It lists generative tools used for research, drafting, coding, client communications, portfolio management and compliance surveillance. The examination items that follow are these.

• Attacks that use the technology. “Threat actors are using SI to automate and accelerate cyberattacks, making those attacks more efficient and harder to detect.” The document says examiners will look at how firms prepare for threats such as “SI-generated phishing messaging and synthetic or deepfake voice and video used for social engineering”.
• Firms’ own use. The document says the Division will prioritise “policies and procedures relating to monitoring SI, including its use in fraud prevention and detection, back-office operations, compliance with AML and Reg BI obligations, and trading functions”.
• Automated advice. For automated investment tools and algorithms, the document says reviews will generally include whether “(1) representations are fair and accurate; (2) operations and controls are consistent with disclosures made to investors; and (3) algorithms lead to advice or recommendations consistent with investors’ investment profiles or stated strategies”.
• Identity theft and market systems. The document says examiners will check whether identity-theft programmes address “emerging risks, such as those related to SI and stolen credentials”, and exchange-system reviews will cover “emerging trends, including SI, tokenization of securities, extended trading hours, and quantum computing”.

Our count: whole-word matches in the text of the two PDFs on sec.gov (2026-exam-priorities.pdf and 2027-exam-priorities.pdf), read on 23 October 2026. Counts can differ slightly with other text-extraction tools.

What Was Posted on X

Cointelegraph posted on X that the SEC announced its fiscal 2027 examination priorities, listing tokenization risks, AI and emerging tech, cybersecurity, investor protection, private funds and credit, and AML compliance.

Where the New Word Comes From

The change comes after Executive Order 14434, “Inaugurating the Era of Super Intelligence,” signed on 29 September 2026. The order says that, “to the maximum extent permitted by law,” executive departments and agencies shall use Super Intelligence and SI in place of Artificial Intelligence and AI in official documents. For now it defines the new term by the existing statutory definition of artificial intelligence.

The SEC’s press release uses the new term too: one of its eight listed focus areas is “Emerging technologies, including super intelligence and other advanced technologies that may affect market operations, compliance, fraud prevention, and investor protection.” The document also says the Division itself is working to “integrate SI responsibly into examinations and risk assessment”, “without displacing examiner judgment”.

One FY 2026 sentence said the Division would “review for accuracy registrant representations regarding their AI capabilities or AI”. In the FY 2027 text we read, the closest line is the general test that representations about automated tools are “fair and accurate”; we did not find a sentence about firms’ claims of SI capabilities.

Private Funds and Private Credit

The same document also covers private markets. For advisers to private funds, the document says examiners will look at disclosures including the “use of debt and fund-level lines of credit”. For registered investment companies (RICs), the document says the Division will continue to monitor developing areas including “less liquid or illiquid investments, including private credit, and the associated issues regarding valuation, redemptions, and disclosures of conflicts of interest and risks”. In its section on broker-dealers’ trading practices, it says the Division will review “the pricing and valuation of illiquid instruments, such as private credit and private equity”.

The document does not mention data centres or AI lending. Our insurers piece reported that US life insurers held about $85.2 billion in AI-related investments at the end of June, according to Moody’s as reported by Bloomberg. As we read it, how such holdings are valued is the kind of question the private-credit items cover in general terms.

Connecting the Coverage

Our executive order piece covered the 29 September order and the agencies that changed their wording after it. Our EPA piece found that the agency’s final FY 2027 Evidence Plan said “Super Intelligence (SI)” where its April draft said “Artificial Intelligence (AI)”. What’s new: the market regulator’s annual examination plan, which advisers and brokers read to prepare for exams, now uses the same term throughout.

The Structural Read

The FY 2026 edition listed fraud prevention and detection, back-office operations, anti-money laundering and trading functions as areas where firms’ supervision of AI technologies would be assessed; the FY 2027 edition lists the same areas, with Reg BI compliance added, for monitoring SI.

On threats, the FY 2026 edition mentioned “new risks associated with artificial intelligence (AI) and polymorphic malware attacks”; the FY 2027 document says “Threat actors are using SI to automate and accelerate cyberattacks, making those attacks more efficient and harder to detect.”

As we read it, the private-credit items sit next to the technology items in the same plan: valuation of illiquid instruments such as private credit, and the use of debt and fund-level lines of credit at private funds.

Three Implications

FOR ADVISERS AND BROKERS The document lists monitoring of SI in fraud prevention, back-office operations, AML and Reg BI compliance and trading functions among the areas examiners will prioritise.

FOR COMPLIANCE TEAMS The FY 2027 document uses ‘super intelligence’ and ‘SI’ where the FY 2026 edition used ‘AI’, and it says the Division is intensifying its efforts to understand how the technologies influence outcomes.

FOR PRIVATE-CREDIT FUNDS The document names valuation, redemptions and conflict disclosures for funds holding private credit, and, in its broker-dealer trading section, the pricing and valuation of illiquid instruments such as private credit.

The Business Engineer Lens

This story maps onto the Business Engineer framework Inside Anthropic’s Permission Layer.

The framework says “The governance layer sits at the intersection of capability, regulation, national security, access control, and geopolitical alignment.”

As we read it, an exam plan is one of the places where that layer meets regulated firms day to day. The framework was published in June 2026 and is about Anthropic; it does not discuss the SEC or this document.

What Is Not Established

The SEC documents we read do not say why the Division changed its wording or whether it considers itself bound by the executive order. The term counts are our own, from the text of the two PDFs. The priorities are a staff statement with no legal force, and the Division says they are not an exhaustive list of what examiners will review. We did not contact the SEC. Nothing here is investment or legal advice.

The Bottom Line

The SEC’s FY 2027 examination priorities use ‘super intelligence’ and ‘SI’ where the FY 2026 edition used ‘AI’, and they list SI-driven cyberattacks, firms’ monitoring of SI, automated advice and private-credit valuation among its areas of focus.