I’ve come across a new document request list for a presence exam from the SEC’s Atlanta Regional Office. The exam period for the letter begins March 31, 2012 – the Dodd-Frank deadline for new advisers to register with the SEC. The SEC has said presence exams will target new advisers or those that manage private funds. The exams also may focus on just one or two topics.
The letter requests investment committee minutes, valuation policies and procedures, any models used in valuing investments, and any third party valuation reports.
Time to sit down and run through a mock document request again.