ADVANCED

Webinar: Should ERAs be thinking about the possibility of an SEC Exam? If yes, what should an ERA do to prepare?

Cordium hosted a webinar on March 11, 2016 that discussed if ERAs should be thinking about the possibility of an SEC Exam and if so, what they should be doing to prepare.

In light of numerous reports late in 2015 that the SEC is changing its practice with respect to auditing Exempt Report Advisers (“ERAs”) more frequently (leaving them subject to the possibility of “routine” audits) AND the fact that the SEC is greatly ramping up in examination resources (i.e. more examiners), ERAs should consider critically reviewing their compliance program and their firm’s adherence to applicable compliance requirements on a regular basis. The SEC has not made an official announcement of this policy change, but senior members of the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) have been quoted acknowledging this change.

Areas of review that ERA’s may want to include:

  • Are internal control procedures consistent with best practice?
  • How are conflicts of interest identified and addressed by the ERA?
  • How are expenses allocated among clients and is it consistent with applicable disclosure?
  • How are investment opportunities allocated among clients and is it consistent with disclosure provided to such clients?
  • How is the ERA dealing with cybersecurity issues?

Presented by:
WGM - WordPress
Bill Mulligan
CEO, Cordium US and Cordium Software

Click here to download the presentation.