Examinations: Best Practices

The list below contains a sample of observed practices that that may assist advisers in designing and implementing policies and procedures under the Compliance Rule

This checklist comes courtesy of Janaya Moscony of SEC3 Compliance Consultants

The latest sweep exam letter reveals a growing sophistication in OCIE’s grasp of cybersecurity

Any CCO should sit in on employee video calls with the SEC, just as a compliance officer—or other firm examination liaison—should be in the room ...

Investment advisers and broker-dealers should take extra steps to make sure they’re validating investors’ identities and the authenticity of disbursement instructions, and have “a trusted ...

The firm was asked to hand over everything from a list of retail customers to fee “grids or schedules” to information on any “bonuses or ...

Document who was involved in the process, the date of a meeting and the result. Commit these items to paper and “your exams are going ...

Investment advisers are already struggling at laying out their firms’ relationship summaries, the SEC says. IAs were required to publish their Form CRS beginning June ...

The SEC’s recent private funds risk alert points to structural problems in the industry—problems that the Commission itself is in a unique position to help ...

New Jersey regulators will examine investment advisers on how well they’re protecting elder clients from fraud, state Attorney General Gurbir Grewal says. The Garden State’s ...