On Thursday, February 20, 2014, the SEC's Office of Compliance Inspections and Examinations (OCIE) issued a news release detailing its plans to conduct examinations of a significant percentage of investment advisers that have not been examined since they registered with the SEC as part of the “Never-Before Examined (or NBE) Initiative.” The examinations will focus on investment advisers that have been registered for more than three years and are not subject to examination under the Presence Exam initiative.
Examinations will concentrate on the investment advisers’ compliance programs, filings and disclosure, and safekeeping of client assets, among others issues. The SEC provided additional details relating to the examinations in the form of a letter directed to the Senior Executive or Principal of a Registered Investment Adviser (the “Letter”). The letter can be found at the following link: http://www.sec.gov/about/offices/ocie/nbe-final-letter-022014.pdf.
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