As a fund manager one of the best ways to be prepared for a visit from the Securities and Exchange Commission is to practice. You should grab a recent document request from a SEC examination. Then give yourself one week to pull all the requested information together in a coherent package.
I put together a collection of SEC Document Requests. Hopefully you might find this collection useful.
By doing a practice run, you will have a collection of documents ready to go if the SEC suddenly arrives. You may also find some weak spots in your internal records.
It gives you a chance to make sure that you know who in the firm is responsible for maintaining the information and that they will keep it update.
Of course, the document request letters vary greatly from the books and records requirements in SEC Rule 204-2. I expect we may see some changes in that rule after the SEC has run through its presence exam program and digested the record-keeping of private funds.
So far, I have seven nine 10 request letter examples plus links to 3 more on IA Watch, but I’m looking for more. If you have an document request example and are willing to share it, you can send it to [email protected]. I will always delete any information about the firm and I will only publish any additional information about the letter that you consent to.
References:
- SEC Examination Document Request on Compliance Building
- SEC Rule 204-2
Photo of Stack of Papers is by Jenni From the Block
CC BY
