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:
- Inadequate Compliance Resources
- Insufficient Authority of CCOs
- Annual Review Deficiencies
- Implementing Actions Required by Written Policies and Procedures
- Maintaining Accurate and Complete Information in Policies and Procedures
- 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!