Published on Sep 29th, 2022 |


Brief Introduction

Vigilant’s Chief Operating Officer, Chuck Martin, provided his insights on BoardIQ that focuses on the SEC’s examination of a Fund’s Compliance with their new derivatives ruling a mere 11 days after the compliance deadline.

Insights From Chuck Martin

In reference to a letter sent by the SEC to the board requesting a plethora of documents related to its derivatives program oversight, Chuck immediately noticed “This is really quick”.

He also commented on the preparation required for such an early request, and the letter tells him that “[the SEC] were planning to immediately add it to their examination of funds.”

Chuck made it clear that this was the earliest he had ever seen exam letters after a compliance date.

Vigilant’s Final Conclusion

This situation demonstrates just how prepared the SEC is to examine any new rules or regulations when there is a compliance deadline. Firms need compliance management with a complete understanding of the new derivatives rule and how their compliance procedures may need immediate adjustment.

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