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Examinations: Best Practices

Young activist holding sign protesting against climate change
The SEC Enforcement Division works with DOE examiners to look for 'misconduct' and using sophisticated data analysis 'to identify potential violations'
'Proactive compliance' comes down to three things, said Enforcement Director Gurbir Grewal. 'That’s what we’re looking for from each of you'
The new ad rule requires firms to be able to substantiate the ads’ claims. 'This is a great tool for us,' said the SEC ...
A clear message being conveyed by the alert is that advisers better be able to 'substantiate material statements' in their ads
The staff will review whether investment advisers have adopted and implemented written policies and procedures that are reasonably designed to prevent violations
The onus falls upon the adviser to confirm that its auditor is both registered and subject to PCAOB inspection
Like cars whipping around a racetrack, some compliance issues have a knack of coming around again and again
Given the many similarities, they could indicate that the ESG questions make up the agency’s current template for ESG exams
One clear takeaway for compliance officers is if your firm claims to invest in accordance with ESG standards, have P&Ps “associated with compliance oversight of ...
A peer shares an SEC exam letter dedicated to ESG

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