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Books and Records Requirements for Investment Advisers
For the average investment adviser, the prospect of managing the administrative and compliance aspects of the daily operations of the firm can be daunting. This pressure is further multiplied by recent regulatory trends and enforcement actions. Given these trends, advisers need to be particularly concerned about the accuracy, quality, and completeness of the firm’s books and records as required by Rule 204-2 of the Advisers Act.
Generally speaking, at the outset of an examination, the SEC will form an early assessment of your firm’s internal controls based upon the quality of your record keeping, and your ability to respond quickly to requests for information. Examiners will ask for numerous records to be available for review, many of which are not "required" records as described in Rule 204-2. Nonetheless, as a registered investment adviser, your firm is obligated to comply with such records requests. In addition, certain books and records may be requested in electronic format to allow for easier analysis of data. These recordkeeping requirements apply to a vast array of topics ranging from the maintenance of the firm’s financial records to records pertaining to the firm’s custody practices.
This seminar will not only cover the nuts and bolts of the SEC books and records rule, including recent amendments, but will incorporate an overview of the SEC’s expectations regarding non-required records that are included in the SEC examination document request list, samples of which will be provided. Paper and electronic storage of records, including email technology and solutions, will be discussed as will record management practices that help advisers avoid common examination deficiencies.
After attending this course, attendees should be able to:
- Implement a holistic and practical approach to books and records management as part of your compliance program
- Distinguish between the Advisers Act Books and Records Rule requirements and non-required records included in the SEC examination document request lists
- Use SEC examination document request lists to test your books and records system
- Update the firm’s books and records policies and procedures to meet SEC requirements and examination expectations
- Manage an organized and efficient records management system to create a resoundingly positive impression at the start of and throughout an SEC examination
- Review books and records tips to avoid common deficiencies
For Whom: Designed to increase the professional competence of investment adviser professionals with legal, compliance and management responsibilities.
Suggested Skill Level: Intermediate
Instructional Method: Group Internet-Based and Group-Live
Pre-requisites for participation: No prerequisites are required. However, attendees can benefit by reviewing the Investment Advisers Act of 1940, especially Rule 204-2, to become familiar with the structure and terms, and sample SEC examination request lists.
Advance Preparation: None