From MCO's August Webinar with NorthPoint Compliance
We recently ran a webinar with former SEC examiners Victoria G. Hogan & Colleen Montemarano of NorthPoint Compliance, who shared their knowledge and insights from a combined twelve years of experience working as SEC examiners.
Here we provide you with some of their recommended Do’s & Dont's for an SEC exam.
1) Prepare Your Office. You will be given notice to inform your staff of their arrival; prepare the office. If it’s a small office, ensure that it is clean and that the examiners will be comfortable. Ask how many examiners will be coming so you can prepare adequate space for them. Examiners often ask for a tour so make sure file cabinets with sensitive documents are locked. If you have a local server room, ensure it is locked.
2) Prepare Your Staff. Have a clean desk policy. This includes not having sensitive information on show, post it notes with passwords and logins for example. Ensure all staff lock their computers when leaving their desk. Make sure they keep the office in a professional manner, keep business discussions to the private areas of the office
3) Ask for Clarification. If a question if it is unclear to you, don’t be afraid to ask them to be more specific, especially if it’s a broad question.
4) Be Friendly and Professional. Although remember to keep a serious tone and dont crack jokes!
5) Make Sure the CCO Sits in On Every Interview. If that happens to be you, then remember to take notes. While you can’t answer your co-workers’ question you can provide clarity or correct them.
1) Ramble. Provide short and concise answers. The interviewer will purposely pause for silences which encourages the interviewee to ramble and disclose information they hadn’t initially intended.
2) Answer with "Yes" or "No". On the other hand, your answers need to be more fleshed out than "yes" or "no".
3) Answer a Question if You Don't Know the Answer. This is a big one. If you don’t know the answer firstly explain yourself and then explain that you can direct them to the person who would know the answer.
4) Make a Joke. It is important that the interview remains serious, and cracking jokes isn’t advised.
5) Answer Any Business Related Questions Unless the CCO is Present. If you do get asked a question while the CCO isn’t present, ask them to communicate the request to the CCO. This is perfectly acceptable.
If you would like to learn more about this subject, you can view the recordings in full from our webinar titled SEC Exam Success here.
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The information in this blog post was provided thanks to the insights of Victoria G. Hogan & Colleen Montemarano, both employees with NorthPoint Compliance
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