SEC Enforcement - Independent Compliance Consultant
Many SEC enforcement cases result in orders or settlements where the subject (for example, an adviser, fund or broker dealer) is required to timely retain the services of an independent compliance consultant (the “Independent Consultant” or “ICC”) that is acceptable to regulators. These subject firms must engage an Independent Consultant to conduct an independent review depending on the details of the order or settlement.
When considering an Independent Consultant to review your business activities, practices or operations, you need to be confident the ICC is sensitive to and able to balance your concerns, including those to your reputation, with the requirements of the SEC order. Our extensive regulatory experience gives both clients and regulators confidence that we will fairly and effectively perform the function of an Independent Consultant.
SEC3 has effectively assisted numerous firms who were required by an enforcement action, deferred prosecution agreement, litigation settlement, or a regulatory or court order to retain an independent compliance consultant.
We are frequently selected by firms — and approved by regulators — because of our experience and considerable knowledge of regulatory requirements and industry best practices. As an Independent Consultant, we have conducted independent and comprehensive reviews of the effectiveness of firms’ governance, compliance programs and other controls.
We have also conducted extensive reviews of supervisory, compliance, and other policies and procedures designed to prevent and detect breaches of fiduciary duties, conflicts of interest, and violations of codes of ethics and federal securities laws. We have also provided recommendations for improving a firm’s policies and procedures.