Mock SEC Exam
How We Help Your Firm Prepare for an SEC Exam
The time you invest in a mock SEC exam with us will save you time and stress during an exam with the SEC. We will identify your firm’s strengths and help you demonstrate to the SEC that you take compliance seriously. You will be calm and organized, which will make for smooth sailing during your document request process and interviews with SEC staff.
What’s Included in the Mock SEC Exam Package?
Through our mock SEC examination, we assess your firm’s risks, identify inconsistencies between your operations and your written policies, and capture areas of potential deficiencies.
We then discuss our findings with you to confirm their materiality, or if they are even applicable to your firm.
We include three months of post-exam consulting to help correct and make any updates to your compliance program, so that you can walk away feeling prepared, refreshed, and confident.
Additionally, unlimited regulatory compliance consulting is a central element of any Core Compliance Service Package.
A mock SEC examination might be the right fit if your firm:
Has had significant changes in key personnel
Has launched a new line of business
Has undergone a merger or acquisition
Has never been examined
Hasn’t been examined in 5 years or more
Mock SEC Exam Case Study
A client on the East Coast that manages over $100 million engaged us for a Mock SEC Exam. They had not been examined in quite some time and knew that some elements of their compliance program might be lacking. If the SEC were to come in tomorrow, they knew their staff would not feel prepared. Using a SEC Exam letter from a recent exam, we shared the requested items with the firm so that they had an idea of what they would need to provide regulators, should they be examined. We started off the engagement by reviewing their key compliance documents (ADVs, policies and procedures, and Advisory Agreements) to understand their firm and identify any gaps of consistency. We had the client produce the requested documents from the letter, with which we performed forensic testing to ensure their policies were in line with actual practice. We mock-interviewed key personnel to give them practice in an exam interview setting and provided feedback and suggestions for implementing best practices. At the end of the mock exam, we provided a summary report, which also served as their annual compliance review for that year.
Our client appreciated the mock process and what we accomplished during the review, so they continued with our full CCO Companion service and received a discount. For the next few years, we worked on forensic testing, annual employee training, and the annual review. The time finally came, and our client received a SEC Exam request of their own. We assisted the client throughout the exam, reviewing documents prior to submission, drafting responses to request letters, and prepping key personnel for interviews. As is not the norm, at the end of the SEC exam, the client received a zero-deficiency letter. They felt prepared and calm to tackle the full exam and have continued to retain SCS for CCO Companion services.
