We profile Raju Hussain, the chief compliance officer at UK-based CVC Capital Partners, in our December/January issue. The following is an accompanied piece to our interview which will be published online next week.
What advice does Hussain, who prior to his appointment by CVC in 2012 was a consultant with a broad range of asset management clients, have for firms going through an SEC examination?
One: Go through a mock exam process. “Complete a mock audit using consultants or lawyers who have done them with other firms in your sector,” he tells pfm. These can either be a routine mock audit or targeted to a specific area of interest to the regulator.
Two: Engage outside consultants to conduct thorough annual reviews.
Three: When the exam, which can last around eight or nine months, is in progress “it is about having a good relationship with the examiners and managing the process well.”
In other words, create an internal team to respond to the initial request list, ensure everyone knows what is required of them and they are able to respond within the timeline – “which in any SEC exam is quite short” – says Hussain. Documents need to be verified internally, which is typically the role of the CCO; data needs to be scrubbed and translated into a format that addresses the question being asked.
“Build the relationship early on,” says Hussain. “If you can’t make the timeline, reach out early for an extension. Have regular catch-ups with the examiners.”