1. fourth Quarter 2018 Members’ Meeting

2. Successful Strategies For Responding to an SEC Letter
S. Kendrick Dunn founder, Jamboree Securities Consulting Inc. Previously, Ken was the Chief Compliance Officer for Pacific Select Distributors, Inc. (PSD) from as well as an Asst. VP of its parent, Pacific Life Insurance Co. from At Pacific Life he was a member of the management team within its Corporate Compliance area. He also consulted to and worked on compliance projects with five broker-dealers that at one time were affiliated with PSD. Ken began his career in the securities industry with the NASD in Los Angeles where he spent over eight years as a supervisor of examiners, managing professionals performing regulatory examinations, addressing membership requests and conducting many forms of “for cause” investigations.  He has also held positions in compliance, administration, human resources and finance (including serving as a FINOP) with several broker dealers including a bank affiliated broker-dealer and two different trading and investment banking firms.  In addition, he consulted to broker-dealers for several years before joining Pacific Life. He was a member of FINRA’s District 2 Committee from and was a member of FINRA’s Dispute Resolution pool.    He has held the Series 7, 24, 27, 51 and 63 registrations.  Ken is a graduate of UCLA with a BA in Economics and he holds an MBA in Finance and Consulting Services from USC.  For additional information, please go to

3. Successful Strategies For Responding to an SEC Letter
Identify (the type of Inquiry)
Plan (Your Strategy)
Gather (Your Response)
Prepare (Your Response)
Anticipate (the Next Inquiry)

4. Identify The Type
Routine
Cause
Sweep
Formal Action

5. plan Your Strategy
“Production” Focused
“Content” Focused

6. Gather (Your Response)
Formats
Hard Copy Documents
Electronic Production
Interviews
Procedures
Other Analysis

7. Gather (Your Response)
Coordinate Production
Technology
Operations
Regulatory/Compliance
Sales/Marketing

8. pRepare (Your Response)
Review All Produced Content For Accuarcy (Look Close!)
Note Any Limits or Changes

9. anticipate (Your Next Inquiry)
Perform Further Reviews
Take Other Remedial Action

10. RESOURCES AND USEFUL LINKS
 SEC Enforcement Manual:
SEC Exam Hotline:
SEC Office of Compliance Inspections and Examinations:
SEC Core Exam Request, Investment Advisors:
FINRA “Targeted Exams” (e.g. sweeps): letters
FINRA Examination Resources:
North American Securities Administrators Association:

11. For Further Questions

12. THANK YOU FOR PARTICIPATING IN TODAY’S MEETING.