SEC Registered Investment Advisers

Mayer Brown a global law firm recently published their very thorough Legal Update on the SEC’s OCIE Risk Alert published on November 19, 2020, discussing its observations from a series of examinations that focused on SEC Registered Investment Advisers related to compliance rule 206(4)-7 under the Investment Advisers Act of 1940.  

The Risk Alert includes a comprehensive set of compliance program deficiencies that OCIE has identified in a sample of deficiency letters from recent SEC Registered Investment Advisers examinations.  Also included in this Legal Update is a link to OCIE’s National Investment Adviser/Investment Company Compliance outreach 2020 seminar focusing on the role of the SEC Registered Investment Adviser’s Chief Compliance Officer.  

From a high level, the Compliance Rule Deficiencies and Weaknesses identified by OCIE in the Risk Alert cover the following topics:

  1. Inadequate Compliance Resources
  2. Insufficient Authority of CCOs
  3. Annual Review Deficiencies
  4. Implementing Actions Required by Written Policies and Procedures
  5. Maintaining Accurate and Complete Information in Policies and Procedures
  6. Maintaining or Establishing Reasonably Designed Written Policies and Procedures

I encourage you to review Mayer Brown’s Legal Update.  If you need assistance with your RIA ongoing compliance requirements, contact us today for your free consultation!

Leave a Reply

Your email address will not be published. Required fields are marked *

XHTML: You can use these tags <a href="" title=""> <abbr title=""> <acronym title=""> <b> <blockquote cite=""> <cite> <code> <del datetime=""> <em> <i> <q cite=""> <s> <strike> <strong>