Since the Madoff Ponzi scheme unraveled, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) has been under the microscope. Wide criticism has been leveled about how the SEC has selected advisers for examination and how the SEC conducts examinations of investment advisers.
The SEC’s responses have included new examination initiatives (primarily involving third-party asset verification of client funds and securities), efforts to increase the expertise of examiners, the appointment of the new OCIE Director Carlo di Florio on January 4, 2010, and a re-evaluation of how OCIE Staff identifies risk…
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