Important Considerations for Your Initial Examination Document Request

In a perfect world, your preparation for a regulatory exam would begin no later than the first day your firm is open for business. Every adviser registered under Section 203 of the Investment Company Act of 1940 (the ’40 Act) is required to make and keep accurate books and records relating to its investment advisory business.

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The Many Recent Signals that Foreshadow a More Aggressive SEC  in Terms of Enforcement Action and Stiffer Penalties for Wrongdoers

The first few months of 2021 have marked a clear shift in how the U.S. Securities and Exchange Commission (SEC) could soon start holding corporations to a much higher standard of accountability for actions that harm investors. A central theme of the SEC’s emerging mindset, as stated in a March 9, 2021, speech by Commissioner Caroline Crenshaw is the belief that corporate culture comes from the top and there is a strong need to incentivize companies to foster a culture of compliance, not misconduct.

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