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News November 8, 2004 Issue

Phone Calls Not a Sweep, Says Source

IM Insight has heard that SEC examiners are calling some large-firm CCOs to ask how they and their firms prepared for October 5. Despite what we’ve heard at recent conferences, do the calls represent an SEC "sweep" of the new compliance program?

No, we’re told by an informed source. They merely represent the first "outreach" by the SEC to help new CCOs implement their compliance programs.

Incidentally, OCIE isn’t using the term "sweep" anymore (officially, at least): the new term is "risk-focused exams" or "risk-targeted reviews." At recent conferences, OCIE general counsel John Walsh has emphasized the menu of inspection approaches that OCIE is employing, ranging from cyclical exams to horizontal exams (where the same issue is reviewed (sweep-like, we might add) at multiple firms) to comprehensive compliance reviews to internal control reviews.