SEC Examinations 2014 – Analysis of New Priorities, Processes & Techni

Information about SEC Examinations 2014 – Analysis of New Priorities, Processes & Techni

Published on August 10, 2014

Author: Miles.Peterson

Source: authorstream.com

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PowerPoint Presentation: SEC Examinations 2014—Analysis of New Priorities, Processes & Techniques ™ Senior Fellow from Practice: Robert Van Grover, JD, Partner, Seward & Kissel Guest Lecturers: John Schneider, CPA, Partner, KPMG Adam Wasserman, JD, Partner, Dechert Patricia Cushing, CPA, Director, Compliance, National Futures Association Fizza Khan, JD, Managing Director & Senior Attorney, CounselWorks Discussion Topics: SEC 2014 Examination Priorities NFA 2014 Examination Priorities Processes & Techniques Reducing Risk of Inquiry by the Division of Enforcement Responding to Deficiency Letters Discussion Topics SEC 2014 Examination Priorities: Conflicts of Interest Safety of Client Assets and Custody Valuation SEC 2014 Examination Priorities SEC 2014 Examination Priorities Continued : Marketing/Performance Expense and Fee Allocation Portfolio Management New Laws and Regulations SEC 2014 Examination Priorities Continued NFA 2014 Examination Priorities: Bylaw 101 NFA Request for Comment CPO/CTA capital requirement and customer protection measures Pool Quarterly Reports Use in selecting firms for examination NFA 2014 Examination Priorities NFA 2014 Examination Priorities Continued: Common Deficiencies noted in NFA Examinations Unlisted Principals Operations inconsistent with disclosure Undisclosed conflicts of interest Inadequate supporting documentation or errors in performance reporting Misleading statements in promotional materials Failure to review trade allocations Failure to accrue for all pool liabilities Pool loans NFA 2014 Examination Priorities Continued Processes & Techniques: Fraud Detection and Prevention Quantitative Analytics Unit Risk Analysis Examination Initiative Examination Referrals Recent enforcement actions arising from referrals “Broken Windows” approach Factors considered when determining whether to refer a matter to OCIE Processes & Techniques Processes & Techniques Continued: Technology New Initiatives Never-Before Examined Advisers Wrap Fee Programs Quantitative Trading Models Presence Exams Processes & Techniques Continued Reducing Risk of Inquiry by the Division of Enforcement: Supervision Disclosure Integration Implementation of Insider Trading Prevention Procedures Risk Assessments and Annual Reviews Reducing Risk of Inquiry by the Division of Enforcement Responding to Deficiency Letters: Balance Silence Approach Counsel Responding to Deficiency Letters

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