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