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OCIE to investment advisers: focus on these five problem areas

Brynn D. Peltz (Goodwin, New York, New York, USA)
Ilan S. Nissan (Goodwin, New York, New York, USA)
Evyn W. Rabinowitz (Goodwin, New York, New York, USA)

Journal of Investment Compliance

ISSN: 1528-5812

Article publication date: 3 July 2017

Abstract

Purpose

To explain a Risk Alert published on February 7, 2017 published by the Securities and Exchange Commission (SEC) Office of Compliance Inspections and Examinations (OCIE) describing the five compliance topics most frequently identified in deficiency letters sent to investment advisers after the completion of an OCIE examination.

Design/methodology/approach

Discusses deficiencies noted by the OCIE relating to the Compliance Rule, required regulatory filings, the Custody Rule, the Code of Ethics Rule, and the Books and Records Rule.

Findings

The OCIE published the Risk Alert with its noted deficiencies only one month after releasing its exam priorities for the year.

Practical implications

All investment advisers should consider reviewing their compliance practices, policies and procedures in light of the deficiencies and weaknesses identified in the SEC Risk Alert.

Originality/value

Practical guidance from experienced lawyers specializing in asset and funds management.

Keywords

Citation

Peltz, B.D., Nissan, I.S. and Rabinowitz, E.W. (2017), "OCIE to investment advisers: focus on these five problem areas", Journal of Investment Compliance, Vol. 18 No. 2, pp. 16-18. https://doi.org/10.1108/JOIC-04-2017-0025

Publisher

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Emerald Publishing Limited

Copyright © 2017 Goodwin Procter LLP.