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baD BOYS

Bad Boys The SEC is Coming For You: Supervision Initiative

The SEC’s Office of Compliance Inspections and Examinations’ 2016 Examination Priorities included a focus on individuals with a history of disciplinary events. That priority has been put into action. The SEC issued a new Risk Alert on upcoming examination. OCIE is undertaking an initiative to examine the supervision practices and compliance programs of registered investment […]

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Rethinking Your SEC Introductory Presentation

I was chatting with a compliance examiner from the Securities and Exchange Commission and heard that the format for private fund exams had changed. Given the complexity and diversity of business models for private funds, the SEC is trying to narrow the scope of its examination. Presumably to help in that effort, the SEC examiners […]

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SEC Exam Results

Securities and Exchange Commission Examiners are beefing up their staff and are more likely than ever to show up on your doorstep. So what are the likely outcomes? The SEC recently announced that it’s shifting resources from the broker-dealer side over to the investment adviser side. It’s leaving the broker dealers for FINRA and putting […]

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US Private Equity Fund Compliance Guide

If you are looking for something to read during the long Thanksgiving Weekend or a great holiday present, pick up a copy of the newly released The US Private Equity Fund Compliance Guide, Volume III. PEI Media just released this follow up that updates the original 2012 edition with the ongoing review and actions of […]

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SEC Meet and Greet – Part 2

Last week I was able to share with you the introductory letter from a firm that recently registered with the Securities and Exchange Commission and quickly received a meet and greet request. That same reader was nice enough to share his experience with me and the readers of Compliance Building. The SEC had a four […]

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SEC Meet and Greet

The Securities and Exchange Commission tackled a large group of new advisers, Post-Dodd-Frank, with the Presence Exam initiative. Then tackled a backlog of exams with the never-before examined initiative. The SEC stated that it wanted to start reaching out to advisers soon after they register to get on top of things from the onset. A […]

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Cybersecurity Sweep Phase 2

According to a story in IA Watch, advisers should expect a second phase of the SEC’s look at cybersecurity. In an interview with IA Watch on March 9, Jane Jarcho, OCIE’s national associate director of the Investment Adviser/Investment Company exam program, described the current thinking behind its “phase 2” initiative around cybersecurity. According to the […]

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Preparation for SEC Examinations

Ascendent Compliance put together a presentation on Preparation for SEC Examinations. Last year the SEC examined 9% of advisers which represent 25% of the RAUM. Of those exams, 87% had deficiencies, 25% had significant findings, and 14% were referred to enforcement. The SEC has implemented a new telephone assessment for offsite remote exams. The examiners […]

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SEC Exam Priorities for 2015

In 2013 the Office of Compliance Inspections and Examinations at the Securities Exchange Commission laid out their examination priorities for 2013 and did so again last year with its 2014 Examination Priorities. OCIE just released its Examination Priorities for 2015. One item jumps out for a focus for private funds: Fees and Expenses in Private […]

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Broker concept.

Private Equity Funds and Broker-Dealer Registration

There was a lots of hand-wringing after a speech by David Blass indicated that the SEC was focusing on transaction based fees that private equity funds were earning on securities transactions. Since then, there has been rumblings during presence exams, but no official enforcement action or ruling from the SEC. One group of fees at […]

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