ComplianceAlert

SEC Issues Alert on Affiliated Transactions

On September 4, 2019, the Office of Compliance Inspections and Examinations (“OCIE”) released a Risk Alert (the “Alert”) on the results of examinations of investment advisers where issues regarding principal and agency cross transactions were discovered. The Alert described common deficiencies found generally, and at private fund firms, specifically. The findings discussed come from examinations…

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ComplianceAlert

New Risk Alert on Supervision and Conflicts

On July 23, 2019, the Office of Compliance Inspections and Examinations (“OCIE”) released a Risk Alert (the “Alert”) on the results of examinations of investment advisers focused on compliance, supervision, and conflicts. The Alert described both common deficiencies and best practices found during 50 examinations conducted in 2017 as part of OCIE’s Supervision Initiative. The…

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ComplianceAlert

OCIE Provides Guidance on Electronic Recordkeeping

The Office of Compliance Inspections and Examinations (“OCIE”) issued a brief Risk Alert ( the “Alert”) on May 23, 2019 describing how firms can successfully manage and store electronic records in a safe and secure manner. The Alert was based upon recent SEC examinations of both investment advisers and broker-dealers and is meant to address…

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ComplianceAlert

New Risk Alert on Regulation S-P

Last week the Office of Compliance Inspections and Examinations (“OCIE”) released a Risk Alert (the “Alert”) on Regulation S-P, the Privacy Rule. The Alert described the most common deficiencies found regarding the Privacy Rule over the past two years of examinations of both registered investment advisers and broker-dealers. The top findings included: Failure to deliver…

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ComplianceAlert

Speech Addresses SEC’s 2019 Rulemaking Agenda

New SEC rulemaking looks to be gaining momentum based on a recent speech by the Director of the Division of Investment Management (IM). Dalia Blass gave the keynote address at the ICI Mutual Funds and Investment Management Conference on March 18, 2019, and although her speech was to a mutual fund audience, many topics presented…

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