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SEC Examinations & CCOs will cover the following topics:        

  • Registration as an investment adviser
  • Exemptions from registration and their implications under the Advisers Act
  • The legal and compliance requirements imposed on investment advisers
  • The role and responsibilities of Chief Compliance Officers, supervisors and others
  • Implementing and administering written policies and procedures for a registered adviser, and for an Exempt Reporting Adviser
  • How to conduct a “not less than annual” review
  • Adviser priorities: the role of senior management, and conflicts and risk identification and resolution
  • OCIE’s priorities for 2013
  • How does the SEC liaise with regulators from other jurisdictions?
  • How are advisers risk-assessed and selected for examination?
  • How should advisers prepare for an examination?
  • Examinations of non-US entities: What the SEC staff is looking for, how they identify which advisers to review
  • Types of examinations, and what happens before, during and after an examination?
  • What follows the examination?
  • Deficiency letters and enforcement trends