Broker-Dealer Records Production Support
An examination request and a litigation document request look similar and are not. One is answered from an archive that was supposed to be compliant all along, and the gap between supposed and actual is where the findings come from. Broker-dealers and investment advisers live under records requirements that are continuous rather than event-driven. When […]
SEC Data Delivery Standards Compliance
PDFs are not an acceptable format for images. Deduplication and AI-assisted review must be approved by Enforcement before you do it. Google Drive and Microsoft 365 links are not accepted. All three are in the SEC’s own specification, and almost nobody reads it before producing. The Securities and Exchange Commission publishes exactly what a production […]
Wells Notice Document Production
By the time a Wells notice arrives, the staff has already read your documents and formed a view. The production that follows is not discovery. It is argument, and it is built from the record you already gave them. A Wells notice tells you the staff intends to recommend an enforcement action. What follows is […]