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SEC’s Division of Examinations (“EXAMS”) issued a risk alert on its Initial Observations Regarding Advisers Act Marketing Rule Compliance (the “Risk Alert”), giving compliance officers an unexpected gift by sharing examples...more
On April 26, 2022, the U.S. Securities and Exchange Commission’s (“SEC”) Division of Examinations (“EXAMS”) issued a risk alert concerning deficiencies related to Section 204A of the Investment Advisers Act of 1940 (“Advisers...more
Rule 38a-1 under the Investment Company Act of 1940 (the 1940 Act) requires funds to review their compliance programs, as well of those of their service providers, including their investment advisers (advisers), annually....more
The SEC's Division of Examinations recently issued a Risk Alert with observations on investment adviser compliance programs, noting numerous deficiencies and weaknesses it has encountered....more
On November 19, 2020, the SEC published a risk alert providing an overview of notable compliance issues identified by the agency’s Office of Compliance Inspections and Examinations (“OCIE”) under Rule 206(4)-7 (the...more
Compliance is a key issue for all firms. Many companies use the U.S. sentencing guidelines as a starting point. In other instances, regulators craft a starting point with rules that direct the creation of programs....more
In a 30-day period, the U.S. Securities and Exchange Commission (“SEC”) has released guidance in three ways regarding certain views on the important role and potential liability risks of chief compliance officers (“CCOs”)....more
On November 19, 2020, Peter Driscoll, director of the Office of Compliance Inspection and Examination (“OCIE”) of the Securities and Exchange Commission (“SEC”), gave a speech urging advisory firms to empower their Chief...more
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
On February 7, 2017, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) published a Risk Alert listing the five most frequent compliance topics identified on investment adviser examinations completed within...more