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:
Click here to download the presentation.