Brynn D. Peltz, Ilan S. Nissan and Evyn W. Rabinowitz
To explain a Risk Alert published on February 7, 2017 published by the Securities and Exchange Commission (SEC) Office of Compliance Inspections and Examinations (OCIE) describing…
Abstract
Purpose
To explain a Risk Alert published on February 7, 2017 published by the Securities and Exchange Commission (SEC) Office of Compliance Inspections and Examinations (OCIE) describing the five compliance topics most frequently identified in deficiency letters sent to investment advisers after the completion of an OCIE examination.
Design/methodology/approach
Discusses deficiencies noted by the OCIE relating to the Compliance Rule, required regulatory filings, the Custody Rule, the Code of Ethics Rule, and the Books and Records Rule.
Findings
The OCIE published the Risk Alert with its noted deficiencies only one month after releasing its exam priorities for the year.
Practical implications
All investment advisers should consider reviewing their compliance practices, policies and procedures in light of the deficiencies and weaknesses identified in the SEC Risk Alert.
Originality/value
Practical guidance from experienced lawyers specializing in asset and funds management.