Mon, Feb 13, 2017
SEC Issues Risk Alert on Top Five Exam Deficiencies
The SEC’s Office of Compliance Inspections and Examinations released a risk alert on the five compliance topics most frequently identified in deficiency letters sent to SEC- registered investment advisers including, but not limited to:
- Compliance Rule: Compliance manuals are not tailored to the advisor’s business practices and/or annual reviews are either not performed or performed inadequately.
- Regulatory Filings: Inaccurate disclosures, untimely amendments to Form ADV, incorrect and untimely Form PF filings, and untimely Form D filings.
- Custody Rule: Advisers did not recognize that they may have custody as a result of certain authority over client accounts.
- Code of Ethics Rule: Access persons were not identified, untimely submissions of transactions and holdings and no description of code of ethics in the Form ADV.
- Books and Records Rule: Books and records are inaccurate or not updated and inconsistent record-keeping
Financial Services Compliance and Regulation
Financial Services Compliance and Regulation
End-to-end governance, advisory and monitorship solutions to detect, mitigate, drive efficiencies and remediate operational, legal, compliance and regulatory risk.
U.S. Compliance Services
U.S. Compliance Services
Comprehensive support for asset managers registering in the U.S.