Recently announced cases against two registered investment advisers and certain of their executives serve as timely reminders of where the SEC is focusing its attention. Although the SEC’s actions are based on alleged intentional violations or disregard of certain regulations, they include important lessons for law-abiding registered investment advisers. Advisers should be aware of the SEC’s focus areas and ensure that the annual review of their compliance program addresses policies related to, among other things:
..their trading policies and, specifically, whether they are conducting any undisclosed principal trading;
..whether they have custody of client assets and, if so, the need to comply with the custody rule;
..whether their compliance policies and program adequately and specifically address their business structures...
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