In addition to exams, OCIE has begun a program to reach out to a firm shortly after the firm first registers with the SEC as an investment adviser. The SEC had a four office pilot program to conduct these meet and greet outreach calls in 2014. The meet and greet outreach program was picked up nationally so this should become more common for new private equity fund managers as they register with the SEC.
In this outreach program, the examiner will send a Meet and Greet Letter requesting a time to talk on the phone. The purpose of the call is to inform newly registered advisers of SEC resources available to them, such as conferences and compliance staff available on a hotline. The SEC also makes note that exams happen and advises on what to expect.
During this call, the meet and greet examiner will ask some basic questions about the firm’s business and what the firm is doing about compliance. Examples of the topics covered are:
- History of the firm and confirm owners
- Does the firm have a compliance program and manual?
- How often does the CCO and employees access the compliance program?
- The business strategies of the funds
- Experience of the leadership of the people of the firm
- Experience of the compliance staff of the firm
- How does the firm communicate track record?
- Affiliate relationships and approvals
- How does the firm satisfy custody?
- What is the firm and the CCO’s biggest compliance challenge?
For firms that are getting ready to register or have registered in the last six months, get ready to answer these questions.
Example of SEC Meet and Greet Letter