SEC Examinations

As fee structures grow more complicated, so must your oversight. Controls at many firms “are not keeping up with the complexity of fees that are ...

An adviser received this initial document request letter in 2019.

Summertime and the living is easy, but that’s not why this is an exciting time for the SEC’s Alicia Tate. “It’s my favorite time of ...

The SEC’s mum about its “upgrade” to how advisers can upload to OCIE materials requested by examiners.   The new system, called Kiteworks, was due ...

Come July, Richard Cody will report to federal prison to begin serving a two-year sentence for investment adviser fraud. But his elderly victims will never ...

Similar to about 40% of advisers, the firm indicated on its Form ADV, Part 1 that it has custody. But when OCIE examiners showed up ...

Retail investors likely would never think to ask to read an adviser’s deficiency letter from the firm’s most recent OCIE exam. But institutional investors aren’t ...

xaminers have frequently observed deficiencies with respect to the custody rule, and in 2017, OCIE issued a Risk Alert identifying some of the typical deficiencies ...

With cybersecurity as hot as a black hole, it’s no surprise that OCIE wants advisers to take a new look at their cybersecurity P&Ps as ...

A glance at a recent OCIE document request letter leaves no doubt of examiners’ interest in advisory fees. This isn’t a state secret given the ...