Have You Heard?
Some SEC examiners are asking advisory firm compliance officers to “write a summary” of all of their material compliance breaches that have occurred since their last exam. In some cases, compliance officers are being asked to certify that they haven’t left anything out.
The good news is that the scope of OCIE’s e-mail requests seem to be narrowing. IM Insight has heard of recent exams where examiners explicitly carved out personal e-mails from the e-mail request. In another exams, they asked for only those e-mails relating to the adviser’s business (presumably allowing them to omit personal e-mails).