Bill Cavell, John McGuire, Partner, Morgan Lewis
Description:
Try reading Rule 204-2 of the Investment Advisers Act and ask yourself if it looks different than an SEC Examination Request Letter. This seminar will not only cover the nuts and bolts of the SEC books and records rule, but will incorporate an overview of the SEC’s expectations regarding records that are to made available during an SEC examination. Paper and electronic storage of records, including email technology and solutions, will be discussed.
For whom:
Chief Compliance Officers and others working in the compliance area, legal counsel, managers
Learning Objectives:
Learn how to implement a holistic and practical approach to books and records management as part of your compliance program. How long should records be maintained and what constitutes a sensible destruction schedule? In what format should they be maintained? Who should be responsible for books and records requirements? An organized and efficient records management system will create a resoundingly positive impression at the start of and throughout an SEC examination.
Pre-requisites for participation:
No prerequisites are required. However, attendees can benefit by reviewing the Investment Advisers Act of 1940 (specifically Rule 204-2), IA Release No. 2204 (available here ) and sample SEC examination request lists.
