Kelley A. Howes

Kelley A. Howes

Morrison & Foerster LLP

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NEP Announces Never-Before-Examined Initiative

The SEC’s Office of Compliance Inspections and Examinations (OCIE) announced this week that its National Exam Program (NEP) launched an initiative to “engage with” investment advisers that have never been examined by the SEC....more

2/24/2014 - Dodd-Frank Form ADV NEP OCIE SEC

Another Bestseller: The SEC’s Examination Priorities for 2014

Following closely on the heels of FINRA’s publication of its examination priorities for 2014 (see our recent client alert), OCIE’s National Exam Program (NEP) released a summary of its 2014 priorities. OCIE’s priorities...more

1/15/2014 - Compliance Databases Dodd-Frank Enforcement FINRA NEP OCIE Third-Party Risk Whistleblowers

SEC Adviser Exams Find Widespread Violations of Custody Rule

The SEC’s Office of Compliance Inspections and Examinations reports finding widespread compliance deficiencies related to custody of securities. In its March 4, 2013 National Exam Program Risk Alert, OCIE said that...more

3/8/2013 - Audits Custody Rule Customer Funds Protection Investment Adviser Investors NEP SEC

OCIE to Target Adviser Payments for Fund Distribution, Funds with “Alternative” Strategies and New Advisers

In an attempt to “increase transparency, strengthen compliance, and inform the public and the financial services industry about key risks,” the SEC’s Office of Compliance Inspections and Examinations (OCIE) published its 2013...more

2/25/2013 - Broker-Dealer Conflicts of Interest Corporate Governance Enterprise Risks Fund Distribution Investment Adviser NEP OCIE Revenue Sharing Risk Management SEC

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