As you will no doubt be aware, the SEC is currently undertaking its annual round of CCO
Outreach meetings around the country. Representatives of Jacko Law Group, PC and
Core Compliance & Legal Services, Inc. recently attended the San Diego CCO Meeting
This year, the SEC staff spent a significant amount of time discussing the top deficiencies
identified during the previous year’s examinations. It is important to be aware of these
deficiencies because they provide an indication of what examiners consider as current
“hot topics”. The Staff is likely to continue focusing on these hot topics in 2008
investment adviser examinations. Therefore, consider whether your internal controls and
policies and procedures address the following areas noted as “deficiencies,” and if
necessary, amend them accordingly to minimize your firm’s risks.
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