Mock SEC / Examinations
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As a result of SCA’s active investment advisory practice, we see SEC comment letters quite frequently. We have a pulse on 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 our examination findings 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
	Regulatory Reporting: 13D, 13G, 13F, Hart Scott Rodino Act, Forms 3,4, and 5 Section 16