Risky Business: Summarizing the OCIE’s Investment Adviser Compliance Risk Alert

The SEC’s Office of Compliance Inspections and Examinations (OCIE) Risk Alert, issued on November 19, 2020, provides an overview of the OCIE staff’s observations from examinations of SEC-registered investment advisers. The alert focused on compliance issues related to Rule 206(4)-7 (Compliance Program Rule) under the Advisers Act, one of the most common sources of deficiencies cited by the OCIE staff. This article summarizes the SEC’s OCIE risk alert and offers practical tips to incorporate the OCIE staff’s observations into existing compliance programs to address the requirements of the Investment Advisers Act of 1940.

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Related Content

• Registered Investment Adviser Handbook Chapter 7: Substantive Requirements (Advisers Act)
  Read this chapter of the registered investment adviser handbook that outlines compliance requirements under the Investment Advisers Act of 1940.
• Regulation of Custodial Practices Under the Investment Advisers Act of 1940, Rule 206(4)-2: Chapter 1
  Review this chapter of the Practical Guidance custody rule outline that addresses application of the custody rule to registered investment advisers and private funds.
• Investment Adviser Compliance Policies and Procedures Checklist
  Consult this handy checklist of compliance policies and procedures that should be undertaken by investment advisers that are registered with the SEC.

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