The process of a mock review is very similar to how an actual SEC Review is conducted. Bates Compliance Group will request specific documents prior to the onsite portion of the engagement. Once the team is on site, either announced or not, they will work with the compliance department in the same manner as the regulators would. They will request specific items of the compliance department, including documents, manuals, client accounts and review items and make notations. No suggestions are made during a mock review, which is usually requested by the board or management to test how their compliance department (including the CCO) would handle an actual review conducted by the regulators. Part of the process is seeing how compliance personnel would fare in their ability to provide the requested documents and their ability to respond to other requests and questioning. Although we will also be reviewing the firm’s compliance program, we are as interested in how the department handles the review.
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