Investment Adviser- Mock SEC Examination

As a result of SCA’s active investment advisory practice, SCA sees SEC comment letters quite frequently. Consequently, SCA has a “finger on the pulse” of the latest SEC exam focus, as well as district office differences. SCA will examine your firm for compliance with SEC requirements and, if requested, issue a confidential report to management outlining SCA’s examination findings, along with recommendations for corrective action. In addition, SCA will assist in creating solutions to the issues identified in the examination. The examinations generally cover the following areas:

• Compliance program rule;
• Form ADV/Brochure disclosure and delivery;
• Client agreements, including solicitor agreements and disclosure letters;
• Portfolio management;
• Privacy policies;
• Compensation /client fees;
• Custody of client funds and securities;
• Advertising, including marketing/performance presentations and website review;
• Wrap fee programs;
• Internal controls;
• Conflicts of interest;
• Code of Ethics, including personal securities trading;
• Insider trading policies;
• Books and records;
• Proxy voting policies;
• Business recovery planning;
• Brokerage practices including aggregation and allocation policies, best execution and soft dollar arrangements;
• Oversight of third party service providers;
• Side by side management issues;
• Side letters;
• Short selling and compliance with regulation M; and
• Regulatory Reporting: 13D, 13G, 13F, Hart Scott Rodino Act, Forms 3,4 and 5 Section 16.