D.E. Scott Investment Management Compliance ServicesD.E. Scott Investment Management Compliance Services

Mock-SEC Examinations

Our review services are designed to assist clients in assessing their “compliance health” and preparing for live SEC inspections. Because our review teams are staffed with seasoned former SEC Examiners with significant in-house experience, the result is a service that not only highlights potential issues, but also offers practical solutions.

Our Mock-SEC Examinations and Annual Reviews include interviews with key personnel and reviews of policies, procedures and working documents in the following areas:

  • Marketing practices and performance composites;
  • Trading practices, including allocation methodologies, best execution, and affiliated transactions;
  • Soft dollars, including trading, products and services, and disclosures;
  • Portfolio valuation, including pricing procedures and fair valuations;
  • Compliance with portfolio guidelines and limitations;
  • Privacy policy and statements;
  • Code of Ethics procedures and reporting, including potential conflicts of interest;
  • Corporate governance and financial records;
  • Registration documents and other required filings;
  • Custody practices, including requirements for pooled vehicles;
  • Anti-money laundering policies and procedures; and
  • Other areas as may be required by your investment and operating activities.

At the conclusion of each review, we provide a detailed report which includes our Results Matrix. Each Results Matrix contains the following information:

  • Outlines of applicable rules and regulations;
  • Details of our observations and findings; and
  • Recommended action items (including SEC expectations and “best practices”).

Limited scope and other targeted reviews are also available.

Key Benefits of a D.E. Scott Review

We use former SEC Examiners to prepare you for live examinations.

  • Every review is managed by a former SEC Examiner.
  • Our document request lists are aligned to those currently in use by the SEC.
  • Based upon your firm’s risks, we rigorously test the areas that may be targeted during your next SEC Examination.
  • Our interview methodology is comprehensive and is designed to help prepare you for live interviews with SEC Examiners.

Every review client receives a comprehensive Results Matrix report.

  • Our Results Matrix is the most comprehensive review report in the industry.
  • Each report provides information for over 100 individual control points.
  • The report provides details regarding the controls tested, including documents reviewed and exam findings.
  • The report serves as a great road-map for ongoing compliance goals.