SEC Mock Exams with Insider Insight
SEC mock exams uncover recurring compliance issues for investment advisers, according to Robert Baker, a former SEC examiner with ACA Group. Smaller firms often face challenges due to limited resources, leading to violations like inadequate custody rule procedures under 17 CFR 275.206(4)-2, such as failing to use qualified custodians or neglecting annual audits. They also struggle with outdated compliance policies and improper fee calculations. Larger firms, with robust resources, encounter issues with nuanced conflicts, such as management fee offsets, undisclosed expense allocations, or marketing rule violations under Rule 206(4)-1, including failure to disclose net performance alongside gross figures. AI is revolutionizing trade monitoring and eComms reviews, but human oversight remains essential to interpret complex data.
Sabal Law PLLC leverages its managing attorney’s experience as a former regulator to guide private funds and FinTech firms through SEC examinations and post exam remediation. More importantly, we craft tailored compliance programs before the exam, ensuring your compliance policies and procedures are reasonably designed to prevent violations of law. Our incubator platform offers subscriptions and alternative fee structures to support emerging managers and growing multi-family offices, easing cash flow concerns. We are fomrer GCs at multi-billion dollar investment managers here to serve as your outsourced general counsel and chief compliance officer. Schedule a Consultation to strengthen your compliance and ace your next SEC exam!