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MAKING SENSE OF DODD-FRANK

The Dodd-Frank Act has broad and deep implications that will touch every corner of financial services and multiple other industries. This site, developed and maintained by attorneys at Stinson Leonard Street, is dedicated to making sense of this complex legislation and helping businesses understand how it will affect them specifically. Our Bloggers ยป

Dodd-Frank

OCIE Issues Alert on the Five Most Frequent Compliance Topics Identified in Examinations of Investment Advisers

by   |   February 8, 2017

The SEC’s Office of Compliance Inspections and Examinations, or OCIE, has published a list of the five compliance topics most frequently identified in deficiency letters that are sent to SEC-registered investment advisers. Within each of these topics, OCIE includes a few examples of typical deficiencies to highlight the risks and issues that examiners commonly identify. The five compliance topics addressed in this Risk Alert are deficiencies or weaknesses involving:

  • Rule 206(4)-7, which is referred to as the Compliance Rule. under the Investment Advisers Act of 1940, or the Advisers Act;
  • Required regulatory filings;
  • Rule 206(4)-2 under the Advisers Act, which is referred to as the Custody Rule;
  • Rule 204A-1 under the Advisers Act, which is referred to as the Code of Ethics Rule; and
  • Rule 204-2 under the Advisers Act, which is referred to as the Books and Records Rule.