OCIE Issues Risk Alert of the Top Compliance Topics

The Office of Compliance Inspections and Examinations' (“OCIE”) National Examination Program issued a Risk Alert of the “Five Most Frequent Compliance Topics Identified in OCIE Examinations of Investment Advisers.”  

The Alert addresses five compliance topics identified in deficiency letters from a review of over 1000 examinations completed over the last two years. The five topics include deficiencies and weaknesses under the Compliance Rule, Regulatory Filings, Custody, Code of Ethics, and Books and Records Rules.

Under the Compliance Rule, examples of deficiencies included compliance manuals not reasonably tailored to the adviser’s business practice; annual reviews not performed or that did not address the adequacy of the adviser’s policies and procedures; advisers not following compliance policies and procedures; and compliance manuals that are not current.

To see the full scope of the deficiencies and weaknesses firms and compliance professionals need to be aware of under each of the five compliance topics, please see the OCIE Risk Letter here.