A Proactive Approach
to Protecting Your Firm
Advisor Guidance’s State and SEC mock examinations help forward-thinking registered investment advisors (RIAs) assess their readiness for a comprehensive compliance examination.
While conducting a mock examination, our team will review your firm’s compliance program to ensure it is adequately designed and effectively implemented in relation to applicable state and federal regulations. During our exam, we will also pinpoint weaknesses based on our most recent experiences with regulatory examiners.
Our mock examination team employs similar procedures, tools, and techniques as state and SEC examiners. Therefore, they can provide your RIA firm with a comprehensive compliance evaluation and an actionable list of items where your organization can improve.
“Our mock examination team consists of former examination and licensing professionals who use similar procedures, tools, and techniques as state and SEC examiners.”
Sam Carter, Director of Registration & Compliance
Key Questions to Consider Before an Examination
Is your firm maintaining proper books and records as required?
Is your Chief Compliance Officer able to quickly retrieve and deliver emails, social media pages, trade blotters, financial statements, and other documents to the examiners?
Are critical components of your compliance program, including your Privacy Policy, personal trading protocols, and procedures around client and public communications fully integrated into your team’s daily activities?
Does your Chief Compliance Officer know and understand the supervisory and compliance oversight responsibilities as described in the compliance manual?
Our SEC & State Mock Examination Process
Once we sign an agreement, we will recommend various methods to securely transmit sensitive, confidential documents for review. We can also execute an NDA to document that your RIA has taken appropriate steps to protect confidential firm and client information.
Our comprehensive mock examination process consists of the following steps:
Data Collection
At the start of every mock exam, we provide your firm with a document request list. The list is similar to the one used by the SEC’s Office of Examinations and is tailored to your firm’s business model and practices — the same way the federal and state regulators develop their document request list.
Once we have gathered all of the appropriate materials, we begin the process of examining your compliance program and books and records.
Compliance Review
Once your firm has satisfied our document request list, our compliance team will familiarize themselves with your firm’s lines of business, operations, and existing compliance program.
During this phase, we will identify deficiencies or findings, or areas requiring additional questioning that could result in follow-on document requests. One of the final steps is to conduct an interview with the CCO and any key associates, principals, or other RIA team members we feel are necessary and could be interviewed by the applicable regulatory examiners. The interview portion helps grow familiarity and comfort, with the hope that you can be prepared for your future “real world” examination.
Presentation of Findings
We provide a written report detailing our findings (unless otherwise requested) and recommendations for areas needing improvement. If preferred, we can present our results via a conference call. This information can be delivered in whatever format your firm specifies.
Recommendations & Guidance
As part of our mock examination project fee, our compliance team may provide your RIA firm with additional hours of consulting following the completion of the exam. This additional service can be provided to help you fill any gaps in your compliance program discovered during the process.
Areas Examined During Our Mock Audit
- Books and Records Retention & Archiving
- Registrations/Notice Filing
- Account Maintenance, Trading
- Client Contracts, Fees & Billing
- Advertising & Marketing
- Custody, Proxy Voting, & Miscellaneous Filings
- Business Continuity/Contingency Planning
- Personal Securities Holdings & Transactions
- Gifts & Entertainment
- Client Complaints
- Privacy & Risk Assessment
- Supervision & Compliance Training
- Cybersecurity
Move Forward with Confidence
Get the compliance answers and support you need to move your financial firm forward with confidence. Talk with one of our compliance experts today.
