On March 23, 2020, the SEC’s Office of Compliance Inspections and Examinations posted an announcement on its website that “in light of health and safety concerns and other circumstances, OCIE has moved to conducting examinations off-site through correspondence, unless it is absolutely necessary to be on-site.”
Similarly, over recent weeks, CSS has arranged with clients to replace its on-site compliance reviews with video conferencing and the secure exchange of data through its encrypted compliance tool, ACM. CSS has full capability to continue risk assessments, annual reviews, mock examinations, due diligence reviews and cybersecurity reviews through this difficult situation.
The SEC announcement also sought to reassure advisers impacted by COVID-19 that relying on the recent exemptive relief that may cause delays in filing Form ADV or delivering material amendments to clients “will not be a risk factor utilized in determining whether OCIE commences an examination.” Be sure to reach out to CSS Client Service teams for questions that you may have. Stay safe and be well.
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