Below are three typical examples of deficiencies or weaknesses with respect to the Books and Records Rule identified by the SEC staff:
- Did not maintain all required records. The SEC staff observed that certain advisers may not have maintained all the books and records required by the Books and Records Rule, such as trade records, advisory agreements and general ledgers.
- Books and records are inaccurate or not updated. The SEC staff observed that certain advisers had errors and omissions in their books and records, such as inaccurate fee schedules and client records or stale client lists.
- Inconsistent recordkeeping. The SEC staff observed that certain advisers maintained contradictory information in separate sets of recor