SEC Mock Examinations
Prepare yourself for a successful SEC Examination
The Securities and Exchange Commission continues to keep true on their promise of heightening the exam pace on Registered Investment Advisers especially those that haven’t been examined in the last three years.
Being prepared is easy. If you already have a compliance program in place your can test the soundness of your compliance program by conducting a Mock SEC Examination. Our mock exam will evaluate the ability and preparedness of your firm’s key personnel, processes and records to determine if your firm’s commitment to compliance is enough to ensure a successful outcome when next examined.
To accurately assess the soundness of your firm’s compliance program we will conduct the Mock Examination which will consist of three different stages:
Off-site Review – First, as the SEC would do, we will request a series of compliance documents to best understand your firm’s unique business practices and then use those documents to prepare us for the on-site stage of the examination.
On-site Mock SEC Exam – Next, we will visit your offices and conduct a series of exercises and interviews designed to simulate and SEC exam to evaluate the performance of the firm, senior staff and appropriate personnel. As in a regulatory examination no feedback will be given during the exam itself but there will be a group wrap-up meeting for all those that were involved where we will provide feedback and coaching to your team that was involved in the mock exam.
The various topics that may be discussed during the staff interview process may include the following:
- Form ADV
- Advisory contracts
- Advisory fee arrangements
- AML procedures
- Best Execution
- Books & records/filing system
- Disaster recovery/Business Continuity program
- Due diligence
- Insider trading policy and Code of Ethics
- Advertising/Marketing materials
- Performance materials
- Soft Dollars
- Trading practices
- Custody Issues
- ERISA matters
- Privacy Rules/Policy
- Conflicts of Interest
- Risk Management
- Compliance Manual/Supervisory Procedures
Off-site Exam Report – Upon completion of the one-site review, we will provide you with a written summary of findings and any recommendations for corrective actions including appropriate follow-up training for specific individuals or you’re firm as a whole.
For more information on SEC Mock Examinations, contact us today.