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SEC Examinations: A More Hostile Approach?

By Michael MacPhail, Esq.

            The SEC examination staff?s use of a new letter request directed to registered investment advisers signals a more hostile approach to industry participants, and raises the risk of unjustified adverse findings of deficiency.  There are two important aspects of the letter, which was sent to an unidentified firm by the SEC?s New York Regional Office sometime in August 2007. See http://nscp.org/media/sec_request_list-aug2k7.pdf.A.        Proof that Policies and Procedures Have Been Implemented             First, the letter highlights the importance of demonstrating compliance with Rule 206(4)-7 under the Investment Advisers Act of 1940 (?Advisers Act?)...continue to full post

Full post as published by NASD, SEC and Regulatory Defense Blog on November 11, 2007 (boomark / email).