What to do Before the SEC Comes
The Securities and Exchange Commission (“SEC”) is continuing to focus on their exam initiative. They are working to complete more exams than ever before, especially for those firms that have not been audited before. One best practice that everyone should implement is to create an introductory presentation for the SEC Examiners.
An introductory presentation is your chance to tell the examiners all about your firm, your business model and your compliance program. This can help the examiners understand how your firm operates and focuses them on the key areas to review for your type of firm.
Remember this is not a sales pitch. You are not trying to sell the examiners on becoming clients, you are trying to help them understand there is no fraud or deception at your firm. A PowerPoint is a very effective format for this presentation and your Chief Compliance Officer needs to be present during the meeting. If your chief Compliance Officer is comfortable presenting, let him/her lead this initial meeting.
So put together a PowerPoint now so you are not caught by surprise and under the gun to produce dozens of documents and try to create a compelling presentation. The presentation should include your organizational structure, firm history, all conflicts of interest, your compliance culture, mission statement, client base, services provided, your marketing strategy and risks.
Also remember this presentation is a living document so you need to update it at least semi-annually so that it remains relevant.