Purpose of the Template
When the SEC Division of Examinations contacts your organization, your response to their initial document request is critical. This template offers a structured framework for organizing and delivering the materials examiners request, while documenting your compliance program's operational state.
The SEC's October 1 handbook, "The SEC Exam Handbook: A Practical Guide on Process and Engagement," clarifies examiner expectations. Your document response protocol should align with these expectations. This template helps you respond systematically to information requests while maintaining defensible records of what you provided, when, and in what format.
Use this template when you receive a document request list (DRL) or when preparing for an announced examination. It's designed for investment advisers, broker-dealers, and other SEC-registered entities under Division of Examinations oversight.
Prerequisites
Before deploying this template, confirm you have:
Authority mapping: Written confirmation of who can authorize document production for each business unit (compliance, trading, operations, legal). Ensure sign-off authority is clearly documented before examiners arrive.
Document retention verification: Evidence that your retention schedule aligns with Rule 17a-4 (for broker-dealers) or Rule 204-2 (for investment advisers). If your policies state you retain emails for three years but you produce only two years, you've created a gap that examiners will notice.
Custodian identification: A current list of custodians for each record category the SEC typically requests. Know where trade blotters are stored, who controls the general ledger, and which system houses your Form ADV amendments.
Production tool access: Confirmed access to your document repository, whether that's SharePoint, a compliance management system, or a secure file transfer protocol. Test your ability to export, redact where legally permitted, and deliver files in the formats examiners prefer.
The Template
SEC Document Response Log
Examination identifier: [Insert exam file number or reference]
Document request received: [Date]
Initial response due: [Date, typically 2-5 business days]
Compliance officer: [Name and contact]
Outside counsel (if engaged): [Firm and contact]
Request Item 1: [Examiner's exact language]
Custodian(s): [Name, title, department]
Source system(s): [Trading platform, email archive, compliance database]
Time period covered: [Specify dates]
Format provided: [PDF, Excel, native file]
Bates range (if applicable): [Start-End]
Date produced: [Actual delivery date]
Delivered by: [Upload link, encrypted email, physical delivery]
Privilege log attached: [Yes/No, if you withheld documents on attorney-client grounds]
Notes: [Any limitations, explanations, or context the examiner should know]
Request Item 2: [Examiner's exact language]
[Repeat structure above for each request line item]
Supplemental Production Tracker
| Request # | Original Due Date | Supplemental Docs Identified | Date Produced | Reason for Supplement |
|---|---|---|---|---|
| 3 | [Date] | [Description] | [Date] | [E.g., "Additional emails located after archive search refinement"] |
Examiner Communication Log
| Date | Method | Examiner Name | Topic | Action Items | Follow-up Required |
|---|---|---|---|---|---|
| [Date] | Phone | [Name] | Clarification on Item 7 scope | Provide last 18 months, not 24 | Response sent [Date] |
| [Date] | [Name] | Request for interview availability | Schedule CFO for [Date] | Calendar hold confirmed |
Interview Preparation Tracker
| Interviewee | Role | Topics (per examiner) | Prep Session Date | Documents Reviewed | Counsel Present |
|---|---|---|---|---|---|
| [Name] | CCO | Compliance testing program, conflicts policy | [Date] | Annual reviews 2022-2024, conflicts register | Yes |
Customizing the Template
Adjust request line items based on your registration type: Broker-dealers will see requests for customer complaint logs and trade surveillance reports. Investment advisers should expect questions about Form ADV accuracy, fee calculations, and custody arrangements. Tailor the template categories to match your regulatory profile.
Scale the Bates numbering decision: If you're producing fewer than 500 pages, Bates stamping may add unnecessary time. For productions exceeding 1,000 pages or involving multiple custodians, apply Bates ranges to maintain clear references during examiner interviews.
Define your privilege protocol upfront: If you're withholding documents based on attorney-client privilege, your privilege log must describe each document without revealing the privileged content. Customize the "Notes" field to flag where you've applied privilege, and maintain a separate detailed log for legal review.
Incorporate your deficiency response process: If examiners identify gaps during the exam, add a "Deficiency Response" section. Document what the examiner flagged, your remediation plan, the responsible party, and the completion deadline. This becomes your roadmap for the post-exam period.
Link to your policies: In the "Notes" field for each request item, reference the internal policy that governs that record type. When you produce trade blotters, note "See Trade Surveillance Policy v3.2, Section 4." This demonstrates that your records align with your stated procedures.
Validation Steps
Cross-check completeness before initial submission: Compare the examiner's DRL against your response log. Every request line should have a corresponding entry. If you can't fulfill a request, document why and communicate that gap to the examiner in writing before the due date.
Verify custodian sign-off: Before you produce documents, confirm that each custodian has reviewed the materials for accuracy and completeness. A trading desk supervisor should verify trade blotters; your CFO should confirm financial statements. Document these approvals in your log.
Test file delivery: Send a small test file to confirm the examiner can access your delivery method. Encrypted email attachments, secure portals, and FTP sites all carry technical risks. Discovering access issues on the due date creates unnecessary friction.
Conduct a privilege review if counsel is involved: If outside counsel is engaged, they should review your production for privileged materials before delivery. Your validation step includes confirming that review occurred and that any privilege log is complete.
Schedule a post-production debrief: Within 24 hours of your initial production, meet with your response team to document lessons learned. What took longer than expected? Which custodians struggled to locate records? Which systems couldn't export in the requested format? Update your template with these insights so your next response is faster.
Maintain version control: Each time you supplement your production or update your log, save a new version with a date stamp. If examiners question what you provided and when, you'll need a clear audit trail of every iteration.
The SEC's expanded handbook signals that the Division of Examinations expects you to engage with the process systematically. Your document response protocol is the first evidence examiners see of how your compliance program actually functions. Make it count.
