If your firm is a registered investment adviser that has never been examined by the Securities and Exchange Commission, you might want to prepare to see SEC examiners in the near future. The SEC staff recently announced an initiative to conduct examinations of a significant percentage of advisers that have not been examined since they registered with the SEC. The SEC staff will focus on advisers that have been registered for three years or more. Private fund advisers are not part of this exam initiative because these advisers are already subject to a separate “presence exam” initiative launched in 2012. If your firm has never had a SEC adviser exam, you will likely receive a letter from the SEC staff describing the exam initiative.
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