The SEC brought settled charges with a $40,000 penalty against a former CCO, Suzanne Ballek, of an RIA for altering records and creating fictitious forms in response to an SEC examination. During the exam, Exam Staff requested the firm’s preclearance policies and procedures as well as documents related to the personal trading activity of one of the firm’s portfolio managers. Before producing these forms, Ballek allegedly modified approximately 170 forms in an attempt to show compliance with the firm’s Code of Ethics and policies and procedures. The SEC noted that the most common alteration she made was changing the dates the forms were signed by the portfolio manager or herself to match the trade date. Apparently, the portfolio manager typically did not fill out and submit the form until after he completed the trade, so many of his forms were signed after the transaction date. For transactions by the portfolio manager for which no form existed, Ballek created a form and included the portfolio manager’s signature on the newly created form without the portfolio manager’s knowledge or authorization. When Exam Staff questioned Ballek about the apparent alterations to the forms, she allegedly falsely claimed that the portfolio manager had filled out the forms incorrectly and that, at the time the forms were submitted to her, she made the changes. This case highlights the importance of completing and reviewing Code of Ethics reporting in a timely manner and why a CCO and compliance staff should never alter or produce backdated documents in an examination. A deficiency letter comment for late reporting is much better than an enforcement action.