SEC Examinations

The new ad rule requires firms to be able to substantiate the ads’ claims. 'This is a great tool for us,' said the SEC ...

A peer shares a DOE exam letter that focused on ESG

A clear message being conveyed by the alert is that advisers better be able to 'substantiate material statements' in their ads

The staff will review whether investment advisers have adopted and implemented written policies and procedures that are reasonably designed to prevent violations

The onus falls upon the adviser to confirm that its auditor is both registered and subject to PCAOB inspection

The staff continued to observe deficiencies relating to supervision, including many of the same types observed in the 2017 Risk Alert



Given the many similarities, they could indicate that the ESG questions make up the agency’s current template for ESG exams

One clear takeaway for compliance officers is if your firm claims to invest in accordance with ESG standards, have P&Ps “associated with compliance oversight of ...

It’s smart to be nimble during an SEC exam. 'Be ready to pivot' and prep your staff that examiners can turn on a dime and ...