Common SEC Exam Deficiencies
Join us to hear from experienced industry professionals as they discuss common SEC Exam deficiencies! The panel will tackle topics covering:
Common SEC Exam Deficiencies
- The Shifting Landscape of SEC Exams –SEC exam priorities have evolved over the past year, including the most common focus areas and unexpected trends firms should prepare for.
- Marketing Rule Missteps – Where firms are still struggling with compliance under the SEC’s Marketing Rule, including performance presentations, testimonials, and substantiation requirements.
- Compliance Programs That Don’t Keep Pace – How examiners are scrutinizing outdated policies, lack of testing, and firms that fail to adapt their compliance framework to new regulations and business changes.
- Regulatory Expectations vs. Reality – Key areas where firms think they are compliant but fall short in SEC exams, from conflicts of interest management to oversight of third-party vendors.
- Lessons from the Field: What Separates Strong Compliance Programs from Deficient Ones – Real-world insights from Salus GRC consultants, our Law Firm Partner and CCO Panelist, on what firms are doing right, what’s leading to deficiencies, and best practices to stay ahead of regulatory scrutiny.
Speakers
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Aaron GilbridePartner, Latham & WatkinsAaron Gilbride advises clients on complex matters involving federal securities and banking laws.
Leveraging over 15 years of experience across government and private practice, including with the US Securities and Exchange Commission’s Division of Investment Management, Aaron represents:
Investment advisers
Private funds
Registered funds
Fund directors
Financial institutionsAaron regularly advises clients on SEC examination and enforcement investigations. He also counsels corporate clients on matters that could give rise to regulatory issues under the Advisers Act and 1940 Act, including mergers and acquisitions, IPOs, financings, and emerging company matters.
Before joining Latham, Aaron spent nearly six years in senior leadership roles at the SEC, including as Branch Chief in the Chief Counsel’s Office of the SEC’s Division of Investment Management, where he oversaw no-action letters, exemptive applications, and interpretive guidance. Aaron also collaborated closely with the SEC’s Office of Compliance Inspections and Examinations (now Division of Examinations) and Division of Enforcement, with a focus on examinations and enforcement actions involving investment advisers and private funds.
While at the SEC, Aaron also served as Senior Counsel to the Director of the Division of Investment Management and as a principal staff member on the Volcker Rule Interagency Group, where he focused on issues relating to private funds.
Aaron also served on the staff of three Members of Congress, where he focused on a variety of regulatory matters including financial services, economic policy, budget, and trade.
Aaron is an active thought leader and has spoken at numerous events, including conferences hosted by the Investment Adviser Association, Investment Company Institute, and NSCP. He has also served as a member of the New York City Bar Investment Management Regulation Committee and as a member of the Investment Company Institute Outside Counsel Advisory Committee.
