SEC Examination Support for Registered Investment Advisers
Experienced Guidance Once an SEC Examination Begins
ClearView helps SEC-registered investment advisers navigate examinations from the initial request through document production, interviews, follow-up requests, potential examination findings, and remediation. Our former SEC examiners and exam managers bring firsthand experience with how examinations are conducted, how issues develop, and what can lead to additional inquiry.
Former SEC Examination Experience
ClearView’s team includes former SEC examiners and exam managers with decades of experience conducting, supervising, and managing examinations of investment advisers, including private fund advisers, as well as investment companies.
We understand the examination process from the staff’s perspective, including how examiners review documents, prepare for interviews, identify inconsistencies, develop potential issues, and determine when additional information or testing may be necessary.
How ClearView Supports an SEC Examination
SEC examination support can begin as soon as an adviser receives an examination notification or initial information request. The scope and needs of each engagement will depend on the examination and the issues that develop.
Initial Request and Scope Assessment
Review the SEC’s initial request, evaluate the apparent scope of the examination, identify key areas requiring attention, and help the firm organize its response.
Document Production Review
Review requested documents and information before production to help ensure responses are complete, accurate, responsive, and consistent with the firm’s records, disclosures, and actual practices, while identifying issues likely to generate follow-up questions.
Examination Response Coordination
Help management and compliance personnel organize productions, track requests and deadlines, coordinate responses to initial and supplemental requests, and maintain consistency as the examination develops.
Interview Preparation
Prepare management and employees for examiner interviews by reviewing likely areas of inquiry, relevant documents and disclosures, and the examination process so personnel can respond accurately, directly, and based on their own knowledge.
Potential Examination Issues
Help the firm understand issues raised by the staff, evaluate the underlying facts and regulatory considerations, and determine appropriate next steps.
Exit Conference Preparation
Help management prepare for discussions with the examination staff regarding issues identified during the examination, including reviewing the relevant facts, disclosures, supporting documentation, and any corrective actions taken or under consideration.
Deficiency Response Support
Assist the firm in evaluating examination findings, assessing the underlying facts, and preparing clear and appropriately supported responses to deficiency letters.
Remediation and Follow-Through
Help the firm develop, document, and implement practical remediation measures in response to examination findings and other issues identified during the examination.
Former SEC Examination Experience Applied to Your Response
ClearView does not approach an SEC examination as a theoretical compliance exercise. Our team has conducted and supervised examinations from inside the SEC’s Division of Examinations.
That experience helps us evaluate documents, facts, disclosures, and potential issues from the perspective of an examination team while helping the adviser organize its response and address issues as they develop.
Related ClearView Services
ClearView offers a range of complementary compliance services for registered investment advisers.
Mock SEC Examinations
Prepare before an actual SEC examination by testing the firm’s compliance program, disclosures, controls, and practices from an examiner’s perspective.
Learn moreAnnual Compliance Reviews
Risk-based annual compliance reviews designed to identify compliance risks, gaps, and remediation priorities before they become examination issues.
Learn moreMarketing Rule & Advertising Reviews
Focused reviews of advertisements, performance presentations, testimonials, endorsements, and related disclosures for compliance with the SEC Marketing Rule.
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 moreFacing an SEC Examination?
Talk with a former SEC examiner or exam manager about the examination, the issues the staff is focusing on, and how ClearView can assist.