A major SEC objective this year is to increase the frequency of their onsite examinations. Firms need to not only prepare for an inspection of their compliance program, but also for SEC in-person interviews of key firm employees. These employees may include the CEO, COO, CFO, Head Trader, CIO and Senior Analyst, among others. The interviews of key firm employees during an SEC’s onsite portion of an exam allow the SEC to get a better understanding of firm activities directly from the individuals who are responsible for each of those activities. Importantly, the SEC uses the interview as a double check on information discovered during the document review process. The SEC also wants to see if answers tend to change depending on who is answering the question. A lot of inconsistent responses are a sign to the examiners that actual functions may not be in line with firm policies. Finally, the SEC will be interested in not only what you say, but how you present yourself. In other words, how you look, act and speak also play an important part in achieving success in an SEC exam interview.
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