SEC Examinations

The adviser wraps up an SEC exam that focused on fees and expenses

Adviser mistakes ranged from having inadequate compliance P&Ps to omitting compensation conflicts in Form ADV brochures, failing to monitor for the accuracy of client fee ...

"This topic has been, and continues to be, an area that warrants routine review by the staff during adviser examinations. The staff’s observations and examination ...

SEC examiners have been asking private fund advisers about their need to extend their funds, likely probing concerns rattling around the industry about private credit.

The bad news is, private equity managers must keep passing the fees and expenses test

Examiners asked about private fund 'extensions,' or moves by a fund GP to lengthen a fund’s term, perhaps as a means of giving the adviser ...

This PE exam letter speaks to the wisdom of tracking portfolio company transactions with adviser affiliates

Examiners asked to see a 'schedule of any transactions known to the Adviser or its officers between portfolio companies and' other portfolio companies, clients, the ...

The most challenging aspect for smaller advisers will be to persuade large vendors to report any breach within 72-hours. In response to a question about ...

The adviser had to submit a 'list of all intermediary broker-dealers, or other entities, that play(ed) a role in effecting the transactions of structured notes' ...