These are examples of best practices for an investment adviser firm during a routine examination by the SEC or a state securities regulator. This checklist covers the following periods associated with an investment adviser examination: (a) after notification but prior to the interview or visit by the securities regulator; (b) during the visit; (c) during an interview; and (d) after the interview/visit. This list shouldn’t be considered a comprehensive of all possible issues or best practices. This sample checklist is not a substitute for working with a compliance professional and legal counsel.
This sample form should be considered as a starting point; the investment adviser firm will need to customize this sample form to its business model and policies and procedures. Please see our disclosure about the limitations of sample form at http://www.ria-compliance-consultants.com/ria_express_investment_advisor_compliance_tools/sample-forms/
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Included with Bronze, Silver, Gold and Platinum. Initially posted in August 2018. Last updated in January 2022.
Related Forms & Webinars
SEC Exam – Privilege Log
SEC Exam – Log of Requested Docs & Info
SEC Exam – Investment Adviser’s Confirmation of New Deadline for Response
SEC Exam – Response to Deficiency or Findings Letter from Securities Regulator
SEC Exam – Sample Letters Requesting Confidential Treatment under FOIA
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This sample document should be considered a starting point, and purchaser should not treat this sample document as a final document ready for use. The sample document has not been customized to the purchaser’s business model, the specific investment advisory rules applicable to the purchaser’s investment adviser or the written supervisory procedures and code of ethics of purchaser’s investment adviser.
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This sample document is not intended to detect or prevent fraud, selling away, Ponzi schemes, undisclosed outside business activities, inaccurate or false fee calculations, theft, misappropriation or unlawful conversion of client funds.
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