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