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Update
on SEC IA Exam Results
-Hot Topics For 2006-
Based upon recent information disclosed by the Securities
and Exchange Commission ("SEC"), more than 1500 investment
advisory firms around the county were examined in 2005. The examination
staff cited deficiencies in a significant number of those examinations
Interestingly
enough, about half the deficiencies found continue to be related
to inaccurate, incomplete or misleading disclosures on Form ADV.
The other half relate to problematic disclosure of business practices
and fees charged to clients.
Based upon a
review of the deficiencies, it appears hot topics for 2006 will
include:
- Fair valuation
of securities
- Fund expenses
- Proxy voting
- Compliance
programs
- Performance
- Allocations
- Personal
securities trading
- Fund brokerage
for sales
- Soft dollars
procedures and disclosures
- AML
- Misappropriation
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