2013 SEC Annual Exam

SEC Annual Review

Request An Annual Review Consultation

Any Investment adviser that is registered with the SEC must comply with certain annual updating and review requirements under the Investment Advisers Act of 1940. These reviews must be thorough and precise. Specifically under Rule 206(4)-7 (the Compliance Rule) of this Act, investment advisers are required to at least annually review it’s policies and procedures that are established under this rule. This annual review must consider any compliance matters that arose during the previous year, any changes in the business activities of the investment adviser or its affiliates, and any changes in the Advisers Act or applicable regulations that might suggest a need to revise the policies or procedures. The annual review itself must also be well documented by the investment adviser.

Another important matter that must be addressed is the investment adviser’s Compliance Manual. The manual itself must be reviewed for any needed modifications or updates. Also, all employees of an investment adviser must read (or reread) the compliance manual and document that they have read and understand it.

Other items of note that must be reviewed annually include:
Privacy policy notices
Code of ethics
Anti-Money Laundering (AML) policies

These policies, as well as many more, are involved with the Annual Review that must conducted for each investment adviser. The professionals at Cobia Compliance will work with you to ensure that your firm is prepared for its annual review and assist with corrective adjustments where needed. 

For more information on what items are requested by the SEC for an adviser exam, take a look at the attachments below.  One is a "short form" list that is commonly used for a limited scope exam.  These are sometimes used for newly registered advisers. The second form attached is a "long form" list that is used in most adviser exams.  While the SEC requests can sometimes vary by region, these lists are a good point of reference.  If your firm received one of these requests would they be ready?  The first step in answering that question is contacting Cobia Compliance today for a consultation to determine your firm's readiness for your Advisory Annual Review.

Short Form

Long Form