A Checklist to Prepare Traders for SEC Exam Interviews

When examiners from the SEC’s Division of Examinations conduct on-site exams of registered investment advisers, they typically ask to interview various employees. For example, examiners may want to interview traders to better understand how client trades are placed. Thus, it is important that advisers prepare their traders for those interviews. This article examines why SEC examiners may want to interview investment advisers’ traders; explains why advisers need to prepare traders to answer examiner questions; and provides a checklist of questions developed by a former SEC examiner that advisers can use to prepare traders for exam interviews, as well as review their overall trade procedures to ensure compliance with SEC rules and their own compliance programs. See “Private Funds Top the SEC’s 2022 Exam Priorities” (Jun. 9, 2022).

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