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IA Watch published
a few recent document request letters in connection with SEC examinations of
investment advisers. One is a document
request letter sent to a private fund manager (subscription required; 7-day free trial available).
These are some of the items requested that caught my
It's clear from the letter that examiners are focused on
custody issues and side pocket issues.
The SEC has been up front about this. The custody rule
may be a headache, but its intended to prevent another Madoff. By getting
account statements directly from the custodian instead of the adviser, you have
a control in place to prevent fraud.
additional commentary on developments in compliance and ethics, visit Compliance Building,
a blog hosted by Doug Cornelius.
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