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Vedder Thinking | Events Deborah Bielicke Eades to Speak on Books & Records for Investment Advisers for NRS


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October 13, 2011

Speaker: Deborah Bielicke Eades of Vedder Price will be speaking on Books and Records for Investment Advisers for National Regulatory Services.

Description: For the average investment adviser, the prospect of managing the administrative and compliance aspects of the daily operations of the firm can be daunting. This pressure is further multiplied by recent regulatory trends and enforcement actions. Given these trends, advisers need to be particularly concerned about the accuracy, quality and completeness of the firm's books and records as required by Rule 204-2 of the Advisers Act.

Generally speaking, at the outset of an examination, the SEC will form an early impression of your firm's internal controls based upon the quality of your record keeping, and your ability to respond quickly to requests for information. Examiners will ask for numerous records to be available for review, many of which are not "required" records as described in Rule 204-2. Nonetheless, as a registered investment adviser, your firm is obligated to comply with such records requests. In addition, certain books and records may be requested in electronic format to allow for easier analysis of data. These record keeping requirements apply to a vast array of topics ranging from the maintenance of the firm's financial records to records pertaining to the firm's custody practices.

This seminar will not only cover the nuts and bolts of the SEC books and records rule, including recent and imminent amendments, but will incorporate an overview of the SEC's expectations regarding non-required records that are included in the SEC examination document request list. Paper and electronic storage of records, including email technology and solutions, will be discussed as will record management practices that help advisers avoid common examination deficiencies.

Learning Objectives:

After attending this course, attendees should be able to:

  • Implement a holistic and practical approach to books and records management as part of your compliance program
  • Use knowledge of the Advisers Act Books and Records Rule to distinguish between the rule requirements and non-required records included in the SEC examination document request lists
  • Update the firm's books and records policies and procedures to meet new SEC requirements and examination expectations
  • Manage an organized and efficient records management system to create a resoundingly positive impression at the start of and throughout an SEC examination
  • Use books and records tips to avoid common deficiencies

For Whom: Chief Compliance Officers, Ethics Officers, Compliance Staff at all levels, Management, Legal counsel, Auditors

Suggested Skill Level: Basic to Intermediate

Instructional Method: Group-Internet-Based and Group Live

Pre-requisites for participation: No prerequisites are required. However, attendees can benefit by reviewing the Investment Advisers Act of 1940, especially Section 206 & Rules 206(4)—1 (Advertisements) & 204-2 (Books & Records) to become familiar with the structure and terms.

Continuing Education Credits:
See NRS Continuing Education Guide
Recommended CPE Credit: 2

To register please follow this link.

Date and Time:
October 13, 2011, 1:00 p.m. – 3:00 p.m. (ET)



Deborah Bielicke Eades