Tag: OCIE

Compliance Lessons Learned in 2019

Now that we are in mid-January, a few things are evident. We have likely broken one or more New Year’s resolutions, the effect of any rest over the holidays has worn off and we need to complete our annual compliance reviews for 2019 and firm up our 2020 plans. While I don’t have solid advice … Continued

SEC Sets Clear Expectations Regarding Registered Investment Companies’ Compliance Programs

Chief Compliance Officers, Trustees and Service Providers to registered investment companies (RICs) be fair warned … the SEC’s Office of Compliance Inspections and Examinations (OCIE) has issued a Risk Alert identifying the most common deficiencies identified in examinations of RICs and providing observations with respect to money market funds and target date funds. With respect … 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

SEC OCIE Issues 2019 Examination Priorities

Well ahead of the New Year, the SEC Office of Compliance Inspections and Examinations (OCIE) announced its 2019 examination priorities. In keeping with OCIE’s four “pillars” of promoting compliance, preventing fraud, identifying and monitoring risk, and informing policy, the Dec. 20 release provides a preview of key areas where OCIE intends to focus its limited … Continued

SEC Retail Investor Focus Turns Towards Registered Investment Companies

Earlier this year when the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) announced its 2018 examination priorities, OCIE stated that a core priority was to protect retail investors, including seniors and individuals saving for retirement. OCIE is now continuing this effort by focusing on mutual funds and exchanged-traded funds (together, the “Funds”) as the … Continued


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