Inside the SEC Exam Process: Insights from Former Examiner Alicia Minyen

Inside the SEC Exam Process: Insights from Former Examiner Alicia Minyen

For many registered investment advisers, an SEC exam is one of the most significant regulatory events a firm will face. Preparation often determines the outcome, and that preparation is where experience matters most.

Alicia Minyen, a senior compliance consultant and outsourced chief compliance officer at Adviser Compliance Consulting (ACC), spent years on the other side of the table as an examiner in the SEC’s Division of Examinations. During that time, she led and conducted hundreds of examinations of registered investment advisers and investment companies. Her work focused on evaluating whether firms’ compliance programs were effective in practice, not just on paper.

Today, Alicia uses that experience to help advisers understand how regulators evaluate firms and how to prepare for regulatory scrutiny.

Inside the SEC Examination Process

SEC exams are designed to test whether a firm’s compliance program meets the requirements of the Investment Advisers Act and functions effectively across day-to-day operations.

During her time at the SEC, Alicia reviewed many of the areas advisers now recognize as high priorities for regulators. These included portfolio management practices, valuation methodologies, performance advertising and disclosure practices. She also examined emerging areas such as the use of artificial intelligence and algorithmic trading strategies.

Examinations often involved collaboration with other SEC divisions, including enforcement, investment management and trading, and markets. That cross-division coordination can shape how issues identified during exams are evaluated and, in some cases, escalated.

Because she worked within this process, Alicia understands both how exam teams approach an engagement and where firms most often encounter problems.

Why Mock Exams Matter

One of the most effective ways for advisers to prepare for an SEC exam is through a mock examination.

Mock exams recreate the structure of a regulatory review. Firms receive document requests like those issued by the SEC. Compliance staff and business leaders participate in interviews. Policies, procedures and disclosures are reviewed alongside operational practices.

The process often uncovers issues firms did not realize existed. In many cases, the gap is not a lack of policies but a disconnect between written procedures and actual practices.

Alicia’s experience leading examinations allows her to approach mock exams the same way regulators do. She knows where to focus, identifying a firm’s highest risk areas that may result in federal securities violations, and crafts effective policies and procedures to mitigate those risks areas regulators care about. For advisory firms, that insight helps turn preparation into a practical exercise rather than a theoretical compliance review.

Compliance Leadership for Growing Firms

Beyond mock examinations, Alicia works with firms that need outsourced CCO and deputy CCO support.

Many advisory firms face the challenge of maintaining a robust compliance program while managing growth, new regulatory expectations and limited internal resources. Outsourced compliance leadership provides access to experienced professionals who can oversee compliance programs, conduct annual reviews and guide firms through regulatory changes.

In this role, Alicia helps advisers design and maintain compliance programs under Rule 206(4)-7 of the Investment Advisers Act, conduct risk assessments and strengthen controls across areas such as disclosures, advertising, cybersecurity and governance.

Her background in forensic accounting and financial analysis also supports clients dealing with complex reporting, valuation or internal control issues.

A Career Built on Financial Oversight

Alicia’s regulatory experience is reinforced by a broader career in financial oversight and audit. Earlier in her career, she worked as a supervising senior accountant at KPMG LLP and held roles with the Federal Reserve Bank of San Francisco and the Federal Deposit Insurance Corporation.

She later served as chief compliance officer at Altura Wealth Advisors, where she oversaw the development and maintenance of the firm’s compliance program.

Alicia is a Certified Public Accountant in California and Oregon and a Certified Fraud Examiner. Her combined experience in regulatory examinations, accounting, financial analysis, and compliance program oversight allows her to approach compliance issues from both a regulatory and operational perspective.

Practical Insight for Regulatory Readiness

SEC exams continue to evolve as regulators focus on new risks, emerging technologies and increasingly complex advisory businesses. Firms that understand how examiners evaluate their operations are better positioned to respond.

Professionals who have conducted examinations themselves bring a practical understanding of that process.

For advisers preparing for regulatory scrutiny, that perspective can make the difference between reacting to an exam and being ready for one.

Ready to Prepare for Your Next SEC Exam?

Whether your firm is anticipating its first SEC exam or looking to strengthen an established compliance program, proactive preparation can make a significant difference. ACC’s mock examination services, outsourced CCO support, and deputy CCO assistance are designed to help advisers identify gaps, strengthen controls and approach regulatory reviews with confidence.

If you would like to learn about how support from Adviser Compliance Consulting can benefit your firm, please contact us to start the conversation.