HighCamp, Your SEC
Compliance Advisor

Industry Challenges

Don’t let the changing regulatory requirements and investor reporting questions keep you up at night. Our former regulators and compliance professionals streamline and organize your compliance processes so you have the peace of mind to know your compliance program passes its next test.

FAQs

When should we expect to be examined by the SEC?

The SEC’s Division of Examinations examines about 15-20 percent of SEC registered investment advisers each year. There are a variety of reasons that advisers are selected for an exam and many of those reasons are in the “routine” category. Advisers that have not been examined and are newly registered (in the past 12 months or so) are most ripe for selection as part of the “never-before examined” initiative.

What are common deficiencies cited by the SEC as part of examinations?

The Division of Examinations issues risk alerts that discuss common examination deficiencies, and are a good inventory of citations. For example, this Risk Alert from 2020 discusses common private fund adviser deficiencies.

What are the most common mistakes that you’ve seen during SEC examinations?

An organized and professional team and high level of common sense are all you need to successfully navigate most examination inquires. That aside, the most common mistake is often not being prepared for the exam, such as: inability to produce records in a responsive and prompt fashion; not adequately preparing employees for examiner interview questions; and not resolving past annual review findings or exam deficiencies.

When should we get a Mock SEC exam?

The is no one size fits all approach to this question. It depends on recent examination experiences (or lack thereof), interested investors, compliance team experience, recent changes to the staff or business, and much more. Every other year seems to be a good industry benchmark.

How are examinations being conducted during the COVID-19 pandemic?

The overall approach to exams during the COVID-19 pandemic has not been that different. The Division of Examinations conducted “correspondent” examinations prior to the pandemic so that is not new. You can expect that the scope of each exam now includes work from home risks. There are pros and cons to not having the physical examiner visit to the office.