News & Analysis as of September 18, 2024

Office of Compliance Inspections and Examinations

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SEC Risk Alert Highlights on COVID-19-Related Compliance Risks and Considerations for Investment Advisers and Broker-Dealers

Akin Gump Strauss Hauer & Feld LLP on 8/21/2020

- The OCIE of the SEC highlights that responses to COVID-19 present important regulatory and compliance issues for SEC registrants, including “heightened risks of misconduct” tied to recent market volatility. - The Risk...more

3 Coronavirus Compliance Tips From the SEC

NAVEX on 8/21/2020

The coronavirus crisis is far from over, and compliance professionals still need every scrap of guidance that regulators can provide about how to run compliance programs in these difficult times. So when the Securities and...more

OCIE Raises Concerns Regarding Physical and Cyber Security, Supervision, and Business Continuity

Perkins Coie on 8/19/2020

The Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission (the SEC) issued a risk alert (the risk alert) on August 12, 2020, highlighting COVID-19 pandemic-related risks and...more

SEC Examiners Warn of COVID-Related Compliance Risks for Broker-Dealers and Investment Advisers

King & Spalding on 8/19/2020

The Securities and Exchange Commission (“SEC”) last week published its observations from the first five months operating the SEC’s national examination program during the ongoing COVID-19 pandemic. This is the latest...more

Private Funds Litigation/Regulatory Year in Review and 2020 Outlook

Pillsbury Winthrop Shaw Pittman LLP on 2/19/2020

TAKEAWAYS - SEC scrutiny of private funds underscores the importance of remaining vigilant, including updating and improving compliance infrastructure and evaluating internal policies and procedures. - Private funds...more

OCIE Publishes Its 2020 Examination Priorities

Jones Day on 1/27/2020

The Situation: The U.S. Securities and Exchange Commission's ("SEC") Office of Compliance Inspections and Examinations ("OCIE") issued its 2020 examination priorities ("Exam Priorities"). The Result: The Exam Priorities...more

Among an Array of 2020 Examination Priorities, SEC Signals Continued Interest in Cryptocurrency

Proskauer - Blockchain and the Law on 1/16/2020

On January 7, 2020, the Securities and Exchange Commission (“SEC”)’s Office of Compliance Inspections and Examinations (OCIE) released its 2020 examination priorities. The majority of OCIE’s priorities for the coming year...more

SEC Exam Priorities For RIAs and ICs

Dorsey & Whitney LLP on 1/15/2020

The Exam Priorities of the SEC’s Office of Inspections and Compliance or OCIE, announced on January 7, 2020 (the “Exam Priorities”), should be a key area of focus for every investment advisor and investment company. The Exam...more

SEC Office of Compliance Inspections and Examinations Issues 2020 Examination Priorities

Foley Hoag LLP on 1/13/2020

On January 7, 2020, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued its annual examination priorities for the coming year (2020 Priorities). The 2020 Priorities are important for regulated entities,...more

Financial Services Weekly News: OCIE Issues Risk Alert On Investment Adviser Principal And Agency Cross Trading Compliance

Goodwin on 9/12/2019

In This Issue. The Securities and Exchange Commission (SEC) issued a risk alert on investment adviser principal and agency cross trading compliance issues, published disclosure interpretations relating to the Inline XBRL...more

Investment Adviser Compliance Index - 2019

Morrison & Foerster LLP on 6/13/2019

The Investment Advisers Act of 1940 (the “Advisers Act”) is the shortest of the federal securities laws enacted after the Great Depression, and the SEC has adopted relatively few regulations under the Advisers Act. As any...more

Newsflash: OCIE Risk Alert Identifies Reg. S-P Compliance Issues

Dechert LLP on 4/23/2019

The Staff of the Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission released a Risk Alert on April 16, 2019, which identifies significant Regulation S-P (Reg. S-P)1...more

The SEC's National Exam Program 2019

Dorsey & Whitney LLP on 1/10/2019

The SEC's Office of Compliance Inspections and Examinations (“OCIE” or the “Office”) announced its 2019 Examination Priorities just before Christmas and the current Government partial-shutdown (here). While nonemergency...more

2019 Examination Priorities of SEC Office of Compliance Inspections and Examinations are Announced

Dechert LLP on 12/22/2018

Next year’s examination priorities of the Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission were announced on December 20, 2018, and cover six broad, albeit...more

Regulatory Monitor: SEC Update

WilmerHale on 5/2/2018

On February 7, 2018, the Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) released its 2018 examination priorities. This year’s priorities comprise five principal areas: (1)...more

SEC 2018 Examination Priorities Match Chairman Clayton’s Priorities as Reflected in the Agency’s Budget Request

Dechert LLP on 3/9/2018

This year’s examination priorities of the Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission (SEC) were announced on February 6, 2018, and cover five broad, albeit...more

Investment Services Regulatory Update - August 2017

Vedder Price on 8/29/2017

On August 7, 2017, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert providing a summary of the staff’s observations from sweep exams of broker-dealers, investment advisers and funds...more

SEC's New Rule Requires Additional Disclosures on Form ADV

Bracewell LLP on 1/30/2017

On January 12, 2017, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) published its 2017 examination priorities.1 OCIE’s 2017 priorities, which largely mirror its 2016 priorities, cover three areas: (1)...more

SEC Issues Guidance on Business Continuity Planning for Registered Investment Companies

Eversheds Sutherland (US) LLP on 7/18/2016

On June 27, the staff of the Securities and Exchange Commission’s (Commission or SEC) Division of Investment Management (IM) issued a Guidance Update on business continuity planning for registered investment companies...more

Investment Management Legal + Regulatory Update - November 2015

Morrison & Foerster LLP on 11/18/2015

Regulation - OCIE Cautions Advisers on Outsourcing Compliance Activities: In a Risk Alert dated November 9, 2015, the SEC’s Office of Compliance Inspections and Examinations (OCIE) said it found that outsourced...more

Investment Management Update - October 2015

Ballard Spahr LLP on 10/15/2015

Below is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry. Schwab...more

SEC brings first cybersecurity-related enforcement action

Robinson+Cole Data Privacy + Security Insider on 10/2/2015

The Securities and Exchange Commission (“SEC”) recently settled its first cybersecurity-related enforcement action against a Missouri based registered investment adviser, R.T. Jones Capital Equities Management, Inc. (the ...more

The SEC OCIE Announces Increased Scrutiny of Broker-Dealers’ and Investment Advisers’ Cybersecurity Programs

BakerHostetler on 9/29/2015

On September 15, 2015, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) issued a National Exam Program Risk Alert (2015 Risk Alert) to provide broker-dealers and investment...more

TN Ethics Opinion Approves Lawyers’ Cloud Storage of Client Data

Burr & Forman on 9/25/2015

Tennessee has joined other states in formally approving lawyers’ cloud-storage of client-confidential data. The Board of Professional Responsibility (“BOPR”) held that lawyers ethically may use cloud storage for...more

SEC Releases First Cybersecurity Enforcement Action for Failure to Protect Client Data

Troutman Pepper on 9/24/2015

The SEC’s focus in the action was not on the manner of the firm’s responses to the breach or whether there was any actual harm, but predominantly on the adequacy of the firm’s written policies for safeguarding customer...more

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