The assistant director of the SEC’s Office of Compliance, Inspections and Examinations (OCIE) recently listed the top 6 SEC examination deficiencies. If you take a look at recent Administrative Proceedings in the compliance Reference Library of CCO Companion, these should come as no surprise:
- Disclosure Documents (late filings, inaccurate and inconsistent documents, failure to provide to clients)
- Code of Ethics (failure to supervise personal securities trading)
- Compliance (failure to have policies and procedures, failure to adhere to policies and procedures, lack of CCO to administer policies and procedures)
- Fiduciary Duty (not acting in a client’s best interests)
- Custody (failure to obtain surprise audit, late financial statements)
- Advertising (misleading or untrue statements, incorrect calculation of performance, claiming adherence to GIPS)
There is not one of these deficiencies that could not have been avoided by having CCO Companion in your compliance arsenal. Not one.