As the magnitude of the measures being taken to mitigate the spread of COVID-19 began to shake financial markets and the very way people do business, we and others began thinking about the implications for the control environments of financial services firms.
The SEC provided its first related release on March 4th offering conditional relief for certain public company filings. Throughout March, additional releases provided relief to market participants from transfer agents to investment advisers. Focusing on the practical matters faced by advisers, SEC3 wrote its first COVID-related release on March 23rd on the subject of working from home. Risk assessment, disclosure, cybersecurity, and information protection were the key topics. These discussions were later expanded in the context of revisiting the national exam priorities in April to include business continuity plans generally and work-from-home procedures specifically as well as electronic communications and books and records. We also wrote a white paper with NSCP Currents in May exploring these and related topics and followed up in August with the compliance risks identified by the SEC related to COVID-19.
Stay tuned as we plan to now provide a weekly series where we revisit these topics and dive deeper into compliance considerations given the current environment. Topics for this series include:
- Business Continuity and Succession Plans
- Supervision of Employees – Work from Home / Remote Location Procedures
- Impacts on Investment Strategy
- Custody and Wire Authorization
- Valuation and Reconciliation
- Electronic Communications
- Cybersecurity and Information Protection
- Extraordinary Business Measures and Disclosure
Also, we hope you can join us – virtually, of course – at our next compliance roundtable Oct 27, 2020. Stay Tuned for details to come.