The SEC requires each advisory firm to identify its unique set of risks as the starting point for developing its compliance policies and procedures. When the SEC’s Office of Compliance Inspections and Examinations visits your office they will want to see your firm’s:
♦ Operational Risk Assessment Procedures
♦ Compliance Review Calendar
♦ Compliance Risk Assessment
♦ Conflict of Interest Assessment
♦ Risk Management Matrix
Can your advisory firm put a check mark next to each of these required documents? If not, it may be the difference between a deficiency letter and referral to the Division of Enforcement.
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