SEC’s Denver Office Sweeps on Advisory Representatives
The SECís Central Regional Office in Denver has sent out a number of nationwide sweep letters, asking advisers to provide information about their advisory representatives and how they are supervised. The letters are dated August 25, and responses are due back by September 24.
Among other things, the letter asks for copies of any standard written agreements between the firm and its advisory representatives, as well as an explanation of how the representatives and their supervisors are compensated. The letter also asks for a copy of the firmís Form ADV and code of ethics (never mind that the compliance deadline of the SECís new Advisers Act code of ethics rule isnít until January 7, 2005).
In other regional office news, the SECís Boston District Office seems to be drilling down into fund access personsí personal trading and possible market timing activities. A mid-August pre-examination document request letter asks for detailed fund flow and transactional information.