In conjunction with a speech delivered by its Director last month, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert discussing significant compliance deficiencies its examination staff had identified relating to Investment Advisers Act Rule 206(4)-7 (the “Compliance Rule”). The alert followed on…
In a speech last month, Peter Driscoll, the director of the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE), stressed that registered investment advisers must take steps to grant authority to their Chief Compliance Officers, pointing out that the failure to do so is often cited as…
The Office of Compliance Inspections and Examinations (“OCIE”) published a Risk Alert highlighting the need for investment advisers to prevent unauthorized access to client data stored on websites. Recently, cyber attackers have used “credential stuffing” and other methods to breach web-based user accounts. Credential stuffing is when a hacker combines…
SEC Issues Risk Alert to Private Fund Advisers, Part 2 This supplements our previous post relating to a Risk Alert issued by the SEC’s Office of Compliance Inspections and Examinations on June 23. The Risk Alert was directed at investment advisers to private investment funds. While the prior post discussed…
Earlier this week, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a risk alert in which it discussed ongoing deficiencies identified during compliance examinations of investment advisers that advise private funds. This risk alert follows on the heels of other SEC activity relating to private fund advisers, including…
As we mentioned in an earlier post, in April of this year the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued separate risk alerts on the subjects of Form CRS and Regulation Best Interest (Reg BI). The risk alerts were designed to provide investment advisers and broker-dealers information regarding…
In our previous post, we described the SEC’s announcement of examination priorities in 2020 for the Commission’s Office of Compliance Inspections and Examinations (OCIE). In that post, we discussed areas of examination that will apply to a large percentage of registered investment advisors and other regulated entities. In this post,…
Earlier this month, the SEC’s Office of Compliance Inspections and Examinations (OCIE) announced its examination priorities for 2020. Many of the priorities listed are similar to those identified in previous years’ priorities lists. The SEC’s approach in addressing them, however, continues to evolve to keep pace with the changing landscape…
The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) released a new Risk Alert on September 4th urging RIAs to review their compliance policies and procedures addressing principal trading and agency cross trading transactions. We pay close attention to OCIE’s periodic Risk Alerts as these publications provide RIAs with not…
A new Risk Alert released by the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) reminds advisers of the added compliance obligations that arise when hiring representatives carrying the baggage of reportable disciplinary histories. While by no means exhorting advisers not to hire such persons, the Risk Alert nonetheless encourages…