Guide · SEC Exam Readiness
SEC Exam Readiness Checklist for Investment Advisers
An SEC examination rarely fails a firm on the existence of policies. It exposes the gap between what the policies say and what the firm can actually show happened. The advisers who come through cleanly are not the ones with the thickest manuals; they are the ones who can produce evidence quickly, consistently, and without a fire drill.
This checklist walks through the areas examiners focus on most and the evidence you should be able to produce on short notice. Use it to find the gaps now, while you have time to close them, rather than during the document request window.
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The core areas examiners test
Exam scopes vary, but a recurring set of themes shows up across most reviews of investment advisers. Each one comes down to the same question: can you show it was operating, not just written down?
- Safeguards and privacy: your Regulation S-P program, incident response, and breach notification readiness
- Books and records: complete, retained, and readily accessible records across every channel business happens on
- Marketing: substantiation for claims and the required conditions for testimonials, endorsements, and performance
- Supervision: written procedures that match how the firm actually operates and are tested, not just filed
- Technology and AI: governance over the tools that now touch client data and communications
The evidence you should be able to produce
When the document request arrives, the difference between a smooth exam and a painful one is whether this evidence already exists in a form you can hand over. If you would have to reconstruct it, that is a gap.
- A current risk assessment and an incident response plan that has actually been exercised
- Proof that communications across email, chat, and collaboration tools are captured and immutably retained
- Substantiation files tied to each marketing claim and performance presentation
- Written supervisory procedures with owners, review dates, and evidence of testing
- An inventory of vendors and AI tools touching client data, each covered by an agreement and your program
Turning the checklist into a standing state
The trap with a checklist is that it describes a moment. You pass it in March and drift out of readiness by June. Regulated firms that stay ready treat these items as continuously monitored controls rather than a pre-exam project.
Centience keeps each of these areas continuously evidenced: monitoring the controls, mapping them to the rules, and holding a timestamped trail so readiness is a standing state rather than a scramble. The free Governance Score runs this checklist against your firm in minutes and shows you exactly where the gaps are.
FAQ
Frequently Asked Questions
How much notice do firms get before an SEC exam?+
It varies, and notice can be short. That is exactly why readiness needs to be a standing state rather than something you assemble after the call. Firms that keep evidence current handle the document request window without a fire drill.
What trips up advisers most often in exams?+
Recurring themes include off-channel communications that were never captured, marketing claims with no retained substantiation, incident response plans that were never tested, and supervisory procedures that no longer match how the firm operates.
Does this checklist cover the Marketing Rule and Reg S-P?+
Yes. Marketing substantiation and Regulation S-P safeguards are both core exam areas covered here. Centience maintains dedicated readiness views for each, mapped to the specific conditions those rules impose.
How do we know where we stand right now?+
The free Governance Score runs this checklist against your firm and returns a 0 to 100 readiness score, a peer benchmark, and your priority gaps mapped to the rules, so you can prioritize the work that matters before an exam.
Run the checklist against your firm in minutes.
The free Governance Score gives you a 0–100 readiness score, a peer benchmark, and your priority gaps mapped to the rules that matter.
Get Your Free Governance ScoreOr call (877) 945-7177