Is your firm prepared for an SEC Exam?
Vigilant Compliance has taken 10 years of compliance knowledge it has developed in the industry and applied it to a Mock SEC Examination Program specifically designed for Investment Advisers and Registered Investment Companies (RIAs). This program will prepare your firm and employees for an SEC exam through a live audit conducted by Vigilant, which mirrors the key procedures followed by the SEC. Our Mock SEC audit also simultaneously test the effectiveness of your compliance program by reviewing various aspects of your firm’s SEC policies and procedures.
What Is a Mock SEC Exam?
Adhering to SEC regulations protects the best interests of your clients, your firm and your associates. A Mock SEC examination shouldn’t cause alarm, but instead offer the opportunity to refresh your associates’ memories with key aspects of regulatory procedures. It’s also a chance to review your existing policies and procedures, and to implement new policies and procedures that comply with all applicable regulatory requirements while not imprudently restricting your operations.
Mock SEC examinations test the preparedness of your compliance program, as well preparedness of your associates when emergencies arise. When testing your policies and procedures, a Mock SEC Exam will encompass the following elements:
- Encompass both On-Site and Off-site Reviews. The SEC will request certain compliance documents to gain a thorough understanding of your firm’s business, policies and procedures. As part of our process, we will request certain documentation and information both prior to and while on-site. With our Mock SEC Exam we attempt to replicate the experience you will have under an actual SEC Exam.
- Interview your associates with mock SEC examination questions. Once the offsite review is complete, SEC personnel will tour your facility and interview key personnel, including senior leadership. The SEC will not provide feedback or guidance during these meetings, but will respond in writing. Vigilant Compliance will conduct a group meeting at the end of the onsite visit and provide advice to you and your associates, thus preparing you for a more positive outcome when the actual SEC exam occurs.
- Provide a written summary of findings. The SEC will recommend necessary corrective actions that must occur for your firm to stay in compliance with the Act. This may include firm-wide or individual training. Vigilant Compliance will provide your firm with a written summary of our findings. We can also conduct training sessions, provide comprehensive compliance consulting services, perform forensic analysis, prepare and submit filings, and develop a written compliance policy that assures your firm’s commitment to the highest ethical standards.
Preparing for an SEC Exam
Consultants from our Boston, New York, Dallas, Philadelphia or Washington, DC offices are ready to help your firm prepare in the likely event of a SEC Examination with our mock SEC exam that will:
- Carefully examine your current policies and procedures, review existing documentation and information, assess firm security and identify key areas of risk and potential scrutiny by the SEC. This process, which can take several days or weeks, may incorporate the entirety of your firm or only the areas of key identified by your firm.
- Provide consulting services after the completion of the mock SEC exam that strengthen your existing policies and procedures, and provide industry best practices and knowledge that will allow you to conduct your business, while not worrying if your firm is in compliance.
Some of the areas the SEC may review include trading, insider trading, marketing and advertising, disclosures, portfolio management, client asset safeguarding, records maintenance, cybersecurity, business continuity, privacy protection and gap analysis.
Contact Vigilant Compliance
Failing to follow SEC regulations results in costly fines, lost clients and a damaged reputation. You can reduce the stress associated with an upcoming SEC examination by working with Vigilant Compliance, a leading global compliance firm. Our experienced professionals bring diverse compliance experience to every client we serve. We can provide outsourced CCO services, comprehensive compliance policy development and implementation, and customized services that target your specific needs and risks.
*Updated November 16, 2017