The Securities and Exchange Commission tackled a large group of new advisers, Post-Dodd-Frank, with the Presence Exam initiative. Then tackled a backlog of exams with the never-before examined initiative.
The SEC stated that it wanted to start reaching out to advisers soon after they register to get on top of things from the onset. A reader of Compliance Building whose firm recently registered received one of these meet and greet letters. He was nice enough to forward it to me to share with the other readers.
Unlike the presence exams or never before examined examinations, there is no document request list. The SEC is letting the firm know that the examiners are out there and keeping an eye on you.
I would expect that the examiner is looking for the newly registered firm to recognize the need for compliance, have a compliance program in place, and to properly manage the potential conflicts in the firm.
I’ll let you know if I hear more.
