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Every registered advisor can expect an SEC staff examination. A major part of the process begins with the SEC document request list sent to the firm prior to the arrival of the examination staff.
To ease your firm through the process of delivering the documents in a timely manner, it's important to ensure that documents are easily accessible. That way, you can quickly produce them from clearly marked files.
But what about situations in which the on-site SEC exam staff makes document requests beyond those you've anticipated? In that case, keep these pointers in mind:
- Ask that the exam staff make each document request in writing.
- Number each request and keep a record of it in a log.
- Keep a copy of each of your responses.
- Have the person(s) who supplied the response sign off on the information.
- Keep a record of who is accountable for producing the information on the business side, as well as who is accountable on the compliance side.
- Attach your response (also numbered) to a copy of the written request.
Jane Worthington is manager of information products at NRS, a division of SourceMedia.
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