Tag: investment adviser exams

Tips to Prevent an SEC OCIE Investment Adviser Exam from Going Bad

Strategies to employ when an SEC OCIE adviser exam goes bad drew a great crowd at the recent CSS Ascendant Fall Compliance Conference. Proactively pointing an exam in the right direction was a consistent theme, summarized by the familiar refrain: “There is no substitute for preparation.” A few keys to note if you find your … Continued

Effective Compliance Policies & Procedures and Annual Reviews: Meeting the Reasonably Designed Standards

Sometimes it seems that enough is never really enough. While compliance officers have grown intimately familiar with SEC Rule 206(4)-7 over the past 15 years since the Rule became effective, deficiencies in connection with the Compliance Program Rule continue to rank among the most frequently cited issues identified in OCIE examinations of investment advisers. It … Continued


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