News & Analysis as of

Ethics Office of Compliance Inspections and Examinations

Dorsey & Whitney LLP

OCIE Observations on Supervision and Compliance for Branch Offices

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The Commission’s Office of Compliance Inspections and Examinations or OCIE issued a Risk Alert on November 9, 2020 centered on questions keyed to supervision and compliance in the context of multiple branch advisories. The...more

Troutman Pepper

Investment Management Update - September 2020

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RULEMAKING AND GUIDANCE - SEC Adopts Amendments to Exemptive Applications Procedures - On July 6, 2020, the U. S. Securities and Exchange Commission adopted rule amendments to establish an expedited review procedure...more

Dechert LLP

OCIE Publishes Risk Alert Regarding Recent Focus Areas in Private Fund Adviser Examinations

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The staff of the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (staff) issued a National Exam Program Risk Alert on June 23, 2020 (Risk Alert). The Risk Alert focuses on advisers that...more

Vedder Price

OCIE Releases Risk Alert Summarizing Observations from Fund Exams and Recent Initiatives

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On November 7, 2019, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a risk alert outlining its top compliance observations from examinations of nearly 300 registered funds conducted over a two-year...more

A&O Shearman

OCIE to Fund Boards: We Are Watching Your Contract Renewal Process

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In a Risk Alert dated November 7, 2019, the SEC’s Office of Compliance Inspections and Examinations reminded investment company advisers and boards that examiners are looking carefully at how firms approach and document the...more

Dorsey & Whitney LLP

SEC Publishes Risk Alert with Observations from Examinations of Mutual Funds, Money Market Funds, and Target Date Funds

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On November 7, 2019, the SEC’s Office of Compliance Inspections and Examinations (OCIE) published a Risk Alert highlighting the most often cited deficiencies and weaknesses observed in recent examinations of registered...more

Sullivan & Worcester

The Top Five "Gotcha" Deficiencies Plaguing Asset Managers and How to Avoid Them

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Let’s start with this caveat: as we all know, under the still-new Trump Administration, priorities may and are likely to change. Now that we got that off our chest, it is nevertheless not the time to sit back and wait. The...more

Kramer Levin Naftalis & Frankel LLP

Funds Talk: March 2017

OCIE Highlights Frequent Topics for Compliance Deficiencies for Investment Advisers - On Feb. 7, 2017, the Securities and Exchange Commission’s (SEC’s) Office of Compliance Inspections and Examinations (“OCIE”) published...more

Dechert LLP

US SEC Publishes Risk Alert on Top Five Investment Adviser Compliance Issues Found During Inspections

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The Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission (SEC) issued a National Exam Program Risk Alert on February 7, 2017 (Risk Alert), highlighting the “five compliance...more

Fox Rothschild LLP

SEC’s Exam Deficiencies

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The SEC recently released its findings relating to exams of investment advisers. In particular, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) found weak compliance programs; insufficient or late...more

Proskauer Rose LLP

OCIE Staff to Examine Registered Advisers' Policies and Agreements for Whistleblower Rule Compliance

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On October 24, 2016, OCIE published a risk alert noting that the SEC exam staff intends to examine registrants' compliance with the Dodd-Frank Act's whistleblower provisions. The alert noted recent enforcement actions...more

K&L Gates LLP

OCIE and FINRA Announce 2016 Examination Priorities

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On January 6 and January 11, 2016, respectively, the Financial Industry Regulatory Authority (“FINRA”) and the Securities and Exchange Commission’s (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”) each...more

Burr & Forman

TN Ethics Opinion Approves Lawyers’ Cloud Storage of Client Data

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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

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