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SEC Examination Priorities Investment Adviser Compliance

K&L Gates LLP

SEC Initiates Sweep of Adviser on T+1 Compliance

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Over the last week, several registered investment advisers have received examination letters, issued from both the Securities and Exchange Commission’s national office in Washington, D.C., and from at least one regional...more

Royer Cooper Cohen Braunfeld LLC

The New Marketing Rule: Notes from the Field

On April 17th, the SEC issued a Risk Alert titled “Initial Observations Regarding Advisers Act Marketing Rule Compliance.” Perusing the list of failures, a sense of familiarity arose, given that one of our clients had been...more

Lowenstein Sandler LLP

SEC Finds Advisers' Compliance with Marketing Rule Still Lacking Despite Examination and Enforcement Focus

Rule 206(4)-1, as amended (the Marketing Rule), continues to be an area of focus for the U.S. Securities and Exchange Commission (SEC). On April 17, 2024, the SEC Division of Examinations (Division) published a risk alert...more

Paul Hastings LLP

SEC Department of Examinations Issues Risk Alert on Marketing Rule Deficiencies

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Last week, the Securities and Exchange Commission’s Division of Examinations (“DOE”) issued a Risk Alert (the “Alert”) entitled “Initial Observations Regarding Advisers Act Marketing Rule Compliance.” The Alert describes...more

Amundsen Davis LLC

Impact of the SEC’s 2024 Examination Priorities Report for Investment Advisers

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The Division of Enforcement (“Division”) for the Securities and Exchange Commission (“SEC”) released the 2024 Examination Priorities Report (“Report”) highlighting the key areas the Division will examine in 2024. The SEC’s...more

BCLP

SEC Division of Examinations Publishes 2024 Examination Priorities

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On October 16, 2023, the Division of Examinations (the “Division”) of the U.S. Securities and Exchange Commission (the “SEC”) published its annual Examination Priorities for 2024 (the “Exam Priorities”). Consistent with the...more

Latham & Watkins LLP

SEC Outlines 2024 Examination Priorities

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The priorities highlight emerging and core risk areas for investment advisers, broker-dealers, and other entities, including cybersecurity and crypto assets. On October 16, 2023, the Securities and Exchange Commission’s...more

Holland & Knight LLP

Thorough Exam: SEC's Division of Examinations Announces Fiscal Year 2024 Priorities

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Amid ongoing federal government shutdown risks and the close of its fiscal year, the U.S. Securities and Exchange Commission's (SEC) Division of Examinations (Exams) recently announced its fiscal year (FY) 2024 priorities....more

ArentFox Schiff

2024 Examination Priorities for Investment Advisers from SEC Division of Examinations

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The US Securities and Exchange Commission (SEC) Division of Examinations recently released its 2024 Examinations Priorities, a yearly report that provides insight into the Division’s areas of focus to improve compliance,...more

Goodwin

SEC EXAMS Division Announces 2024 Priorities Ahead of Schedule

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On October 16, 2023, the SEC’s Division of Examinations (EXAMS) published its exam priorities for 2024. The timing is notable, with the release coming several months ahead of the typical timeline and only eight months after...more

Venable LLP

2024 SEC Division of Examinations Priorities Summary

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The SEC’s Division of Examinations got a head start this fiscal year, announcing its 2024 Examination Priorities (2024 Priorities) at the beginning of the fiscal year for the first time. This novel approach likely signifies...more

BCLP

SEC Staff Provides Guidance on Investment Adviser Examinations

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On September 6, 2023, the SEC Division of Examinations (the “Division”) published a Risk Alert entitled “Investment Advisers: Assessing Risks, Scoping Examinations, and Requesting Documents” (the “Alert”). This Alert offers...more

Foley & Lardner LLP

The SEC Renews its Emphasis on Compliance with the New Marketing Rule

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On June 8, 2023, the Securities and Exchange Commission’s (“SEC”) Division of Examinations (“Division”) released a risk alert (the “Risk Alert”) outlining the SEC’s broadened examination priorities with respect to revised...more

Dorsey & Whitney LLP

SEC Issues Risk Alert on Observations from Examinations of Newly-Registered Advisers

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On March 27, 2023, the SEC’s Division of Examinations (the “Division”) issued a Risk Alert on its observations from examinations of newly-registered advisers. The Division focused on whether newly-registered advisers...more

Dorsey & Whitney LLP

2023 SEC Examination Priorities for Investment Advisers

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The SEC’s Division of Examinations (the “Division”) announced its examination priorities (“Examination Priorities”) for fiscal year 2023. This eUpdate summarizes key points from the Examination Priorities that impact...more

Dorsey & Whitney LLP

SEC Exams of Advisers and Investment Companies

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The Division of Examinations has revamped and updated its exam priorities according to its most recent release, 2023 Exam Priorities. Consistent with its typical approach the Division plans to focus on a blend of topics and...more

Morrison & Foerster LLP

SEC Division of Examinations’ 2023 Exam Priorities – A Continued Focus on Private Funds, Regulation Best Interest, ESG, and Crypto

On February 7, 2023, the Securities and Exchange Commission’s (SEC) Division of Examinations (EXAMs) announced its 2023 Examination Priorities (the “Priorities”), which highlight areas it expects to target in 2023...more

Hogan Lovells

SEC releases 2023 examination priorities for investment advisers

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On February 7, the Division of Examinations within the U.S. Securities and Exchange Commission (the SEC) released its annual list of examination priorities for investment advisers regulated by the SEC under the U.S....more

Vinson & Elkins LLP

SEC 2023 Examination Priorities

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On February 7, 2023, the Securities and Exchange Commission’s Division of Examination (the “Division”) announced its 2023 examination priorities to “provide insights into its risk-based approach, including the areas it...more

BakerHostetler

Top Ten List for Complying with the SEC's New Investment Adviser Marketing Rule

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The Marketing Rule seeks to address evolving changes in advertising and referral practices in the industry – particularly with respect to the use of the Internet, mobile applications, and social media – by providing an...more

Paul Hastings LLP

SEC Publishes Risk Alert Highlighting Focus on New Marketing Rule

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On September 19, 2022, the Securities and Exchange Commission’s Division of Examinations (the “SEC”) published a Risk Alert announcing its intent to conduct examinations focused on compliance with Rule 206(4)-1 (the...more

Morrison & Foerster LLP

Marketing Rule Implementation – Are You Ready for November 4th?

The compliance date for the SEC’s new investment adviser Marketing Rule is November 4, 2022, allowing just over a month for an investment adviser to finalize its implementation process to comply with the Rule, which applies...more

Holland & Knight LLP

Material and Public: Investment Advisers on Notice About MNPI Compliance Concerns

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The staff of the SEC's Division of Examinations (Exam) recently issued a Risk Alert that detailed certain rules registered investment advisers must comply with to prevent the misuse of material nonpublic information (MNPI),...more

Goodwin

SEC’s Division of Examinations Issues Risk Alert Regarding MNPI and Code of Ethics Compliance

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On April 26, 2022, the U.S. Securities and Exchange Commission’s (“SEC”) Division of Examinations (“EXAMS”) issued a risk alert concerning deficiencies related to Section 204A of the Investment Advisers Act of 1940 (“Advisers...more

Morrison & Foerster LLP

SEC Flags Deficiencies in Investment Adviser MNPI Compliance Practices

On April 26, 2022, the SEC’s Division of Examinations (“EXAMS”) issued a risk alert flagging certain notable deficiencies that it has observed related to advisers’ potential misuse of material non-public information (MNPI) in...more

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