The chances are greater than ever that the Securities and Exchange Commission will show up in your lobby. Be prepared and have an introductory presentation for them.
The SEC’s Office of Compliance Inspections and Examinations is continuing on its presence exam initiative. Those exams are shorter which means the examiners can get to more fund managers. For those fund managers that registered before Dodd-Frank, OCIE is rolling out its new Never-Before Examined Initiative.
An introductory presentation is your chance to tell the examiners the story of your firm and the story of your compliance program. If done well, it can show the examiners that you are thoughtful about compliance and keep the examination focused on the right issues.
It’s not an investor pitch. You’re not trying to convince the examiners to invest with you. You are trying to convince them that there is no fraud, deception or manipulation at your firm.
Organize the presentation around a powerpoint and use it as your storyboard. The Chief Compliance Officer should lead the presentation. It may be useful to have one or two key employees present who are involved in the compliance program to help answer questions and take notes.
Put the powerpoint together today. Don’t wait for the SEC document request letter. You will be too busy gathering documents to put together the presentation. You can update the presentation each quarter to keep it up to date. When the SEC says they are coming, you merely need to polish the presentation and not create it from scratch.
Two good starting points are an investor pitch and annual meeting materials. Those should have background information and current investment information that you will want to include. Then you can layer in the compliance program information.
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