CCOs Share Recent SEC Exam Experiences

The SEC Division of Examinations continues to prioritize examinations of advisers that have never been examined or have not been examined for a considerable number of years. To help advisers learn what to expect in those exams, a recent webinar provided an overview of new examination priorities and a step-by-step look at the recent exam experiences of two SEC-registered investment advisers, including the timeline of the exams; the impact of the coronavirus pandemic; document production; asset and custody verification; and the ways those firms navigated the stressful exam process. The presentation featured Krista S. Zipfel and Caleb B. Diaz, director and compliance associate, respectively, at Focus 1 Associates LLC; Abraham J. Freidin, CCO of Capital Counsel LLC; and Jeffrey J. Kearns, president and CCO of Kearns and Associates, LLC. This article distills the key lessons from the discussion. See our two-part series “HFLR Program Explores Current SEC Examination Practices and Issues”: Part One (Dec. 20, 2018); and Part Two (Jan. 10, 2019).

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