Despite the sweeping effects of COVID-19, the SEC is continuing enforcement efforts and is still initiating examinations. In response to the pandemic, there is a heightened focus on firms’ business continuity planning and practices.
Since exams are being initiated during this time, the SEC could contact you for a routine exam with typical request list items. The list may be updated to include requests related to the pandemic.
You also may be contacted by the SEC with a brief request focused solely on your business continuity and pandemic response; you may be asked to provide documentation supporting your firm’s:
- Business continuity plan, policies, and procedures
- Current pandemic response measures, including new additions to existing documentation
- Cybersecurity and employee remote access policies and procedures
- Vendor management practices
WHAT DOES THIS MEAN FOR ME?
Firms must remain ready to respond to full routine exam requests in addition to specific requests related to your firm’s pandemic response. As such, it is important to maintain compliance with the Investment Advisers Act and to update your firm’s business continuity and pandemic response plans as COVID-19-related circumstances evolve.
Fairview can provide guidance and draft documentation to support your firm’s business continuity needs. Reach out to Fairview for more information about how we may be able to assist your firm.