Examination Information Request List
An recent SEC request letter lists 13 items to be provided initially to the SEC, several of which are comprehensive. For example:
- The list of current advisory clients, indicating those that are wrap clients, includes 15 separate pieces of information.
- A record of the names of securities held in all client portfolios. The request letter is accompanied by an attachment describing eight required fields.
- A trade blotter that lists all transactions, including trade errors, cancellations, re-bills and reallocations in securities and other financial instruments (including privately offered funds) for (1) current and former clients, (2) proprietary and/or trading accounts, and (3) access person. There is a three-page attachment describing the 27 fields that are to be included on the trade blotter.
Get a Head Start
Share the request letter with your colleagues, and begin “requesting” the information. Take the time, now, to make sure you are able to gather this information in a timely manner and in the format being requested, so that when the SEC comes knocking on the door (and they will come knocking) you will be prepared!