Mock SEC Examinations for SEC-Registered Investment Advisers
See Your Firm From an Examiner's Perspective
ClearView conducts mock SEC examinations for SEC-registered investment advisers, including private fund advisers. Our former SEC examiners and exam managers evaluate your firm from the perspective of an SEC examination team, focusing on the issues most likely to draw scrutiny and develop during an examination.
Why Firms Conduct Mock SEC Examinations
Prepare Before the Staff Arrives
Give management and key personnel experience responding to examiner-style questions, interviews, and document requests before an actual examination.
Identify Significant Issues Early
Identify potential compliance weaknesses and investor-impacting issues while the firm has an opportunity to evaluate and address them.
Test Whether Policy Matches Practice
Written policies may appear sound. A mock examination tests whether the firm's actual practices, controls, disclosures, and documentation are consistent with those policies.
Give Leadership a Prioritized Plan
Translate examination findings into practical priorities so management can focus attention and resources on the issues that matter most.
Former SEC Examination Experience
ClearView's mock examination team consists of former SEC examination professionals with decades of experience conducting, supervising, and managing examinations of investment advisers, private funds, and investment companies.
That experience gives us a firsthand understanding of how examiners develop a risk profile, evaluate facts, conduct interviews, test records and disclosures, assess potential deficiencies, and determine which issues warrant further attention.
A Risk-Based Examination, Not a Checklist
No two SEC examinations are identical. We tailor the scope of each mock examination to the adviser's business model, activities, conflicts, disclosures, areas of regulatory focus, and other relevant circumstances.
Our approach focuses on the issues most likely to warrant examination scrutiny, including whether the firm's written policies and disclosures are consistent with how the business actually operates.
How a ClearView Mock SEC Examination Works
The scope of each engagement is tailored to the firm, but a ClearView mock examination generally mirrors key elements of an SEC examination.
Risk Assessment & Scoping
We develop an initial risk profile based on the firm's Form ADV, business activities, online presence, examination history, conflicts, and other relevant information.
SEC-Style Document Request
We issue a tailored document request and evaluate the firm's production from an examination perspective, including potential gaps, inconsistencies, and areas warranting follow-up.
Testing & Interviews
Former SEC examination professionals conduct risk-based testing and examiner-style interviews with relevant personnel to evaluate how the firm's compliance program operates in practice.
Follow-Up & Clarification
Potential issues are further evaluated through additional requests, testing, interviews, and factual clarification.
Findings & Practical Recommendations
We explain what we found and why it matters from an examination perspective, and provide practical recommendations for addressing identified issues.
Areas We May Review
Compliance Program & Annual Review
Policies, procedures, annual review, testing, implementation, and remediation of prior findings.
Form ADV & Disclosures
Accuracy and consistency of regulatory filings, client disclosures, and actual practices.
Conflicts of Interest
Identification, disclosure, mitigation, and management of material conflicts.
Fees & Expenses
Calculation, allocation, offsets, and consistency with governing documents and disclosures.
Portfolio Management & Trading
Investment and trading practices, allocations, client restrictions, disclosures, and related controls.
Marketing & Performance
Marketing Rule compliance, performance presentation, substantiation, testimonials, and endorsements.
Personal Trading & Code of Ethics
Code administration, personal trading, access person reporting, and related controls.
Custody
Custody arrangements, identification of custody, applicable requirements, and related disclosures.
Best Execution & Brokerage
Brokerage practices, best execution processes, conflicts, and supporting documentation.
Private Fund Practices
Fund-level conflicts, fees and expenses, allocations, side letters, investor disclosures, valuation governance, and related practices, as applicable.
Regulation S-P & Privacy Compliance
Review of privacy notices, policies and procedures, service-provider oversight, and related Regulation S-P requirements from a regulatory compliance perspective.
Books & Records
Recordkeeping, retention, production readiness, communications, and supporting documentation.
Mock SEC Examination Deliverables
ClearView provides clear feedback on the issues identified during the mock examination, why they may matter from an examination perspective, and practical recommendations for addressing them.
Examination Findings and Observations
Clear identification of potential compliance issues and observations developed during the mock examination.
Risk-Based Testing Results
Results of testing performed on selected compliance controls, records, disclosures, and business practices.
Policy and Disclosure Gaps
Identification of inconsistencies among written policies, regulatory disclosures, client communications, and actual firm practices.
Interview and Process Observations
Feedback on issues identified through examiner-style interviews and evaluation of how key compliance and operational processes function in practice.
Practical Remediation Recommendations
Clear, prioritized recommendations for addressing identified issues and strengthening the firm's compliance program.
Executive-Level Findings Summary
A concise summary of significant findings and priorities to help management and the chief compliance officer focus attention and resources.
Related ClearView Services
ClearView offers a range of complementary compliance services for registered investment advisers.
Annual Compliance Reviews
Risk-based annual compliance reviews designed to identify compliance risks, gaps, and remediation priorities before they become examination issues.
Learn moreSEC Examination Support
Support during an actual SEC examination, including document production, interviews, responses, potential findings, and remediation.
Learn moreMarketing Rule & Advertising Reviews
Independent review of advertisements, performance presentations, testimonials, endorsements, third-party ratings, and related Marketing Rule compliance practices.
Learn moreOngoing Compliance Support
Ongoing compliance assistance for RIAs, including testing, filings, policy updates, remediation, and support for the firm’s compliance function.
Learn morePolicies and Procedures Development
Development and enhancement of compliance policies and procedures tailored to the firm’s business activities, regulatory obligations, and compliance risks.
Learn moreRIA Registration & Form ADV Support
Assistance with investment adviser registration, Form ADV filings and amendments, regulatory disclosures, and related filing requirements.
Learn moreConsidering a Mock SEC Examination?
Talk with a former SEC examiner or exam manager about your firm's regulatory risk profile, examination history, and how a risk-based mock examination can help identify potential issues before an SEC examination.