The Mock SEC Exam Prep Kit

The first 48 hours set the tone

How a firm responds to the initial request letter shapes the entire examination. Assign a single point of contact, confirm scope and the review period in writing, build a production log, and decide how documents will be delivered and tracked before anything leaves the building.

Produce exactly what was asked for, in an organized and indexed form, on time. Volume dumps and late partial productions both invite expanded scope.

• Single point of contact and internal escalation tree
• Written confirmation of scope, review period, and format
• Production log with request-to-document mapping
• Privilege and confidentiality review before delivery

Test your books and records before someone else does

Most deficiencies are records problems rather than judgment problems: missing advisory agreements, incomplete trade blotters, unsupported performance calculations, personal trading reports that were never collected, and marketing materials with no approval evidence.

The kit maps each standard request item to where it should live in your systems, so a gap surfaces during the rehearsal instead of during the exam.

• Advisory agreements and fee schedules for every client in the period
• Trade blotter, allocation records, and best-execution reviews
• Performance calculation support and composite documentation
• Code of ethics reports, pre-clearance records, and gift/entertainment logs
• Marketing files with substantiation and approval evidence

Interviews: prepare people, not scripts

Examiners interview the CCO, portfolio managers, operations staff, and sometimes junior employees. The goal is not rehearsed answers — it is that staff can accurately describe what the firm actually does and know when to say they will confirm and follow up.

The question banks are grouped by role and by topic, including the follow-up questions that typically come after a vague first answer.

• CCO: annual review, risk assessment, testing evidence, escalation history
• Investment team: allocation, suitability, conflicts, personal trading
• Operations: cash movement controls, reconciliation, fee billing
• Everyone: how to handle a question outside your knowledge

Score it, then fix in priority order

The scoring sheet converts findings into a prioritized remediation list weighted by likelihood of examiner focus and client harm. That prioritization is what turns a rehearsal into a work plan — and it becomes contemporaneous evidence that the firm identified and corrected issues on its own initiative.

The kit closes with a deficiency-letter response playbook: how to structure the response, what to commit to, and how to evidence completion.