Simpson Thacher Attorneys Author Article on Registered Investment Adviser Compliance Issues Identified by OCIE
12.30.20
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Partners David Blass and Michael Osnato, Senior Counsel Allison Bernbach, Counsel Meaghan Kelly, and Associates Meredith Abrams and Manny Halberstam authored an article titled, “SEC Risk Alert Highlights Registered Investment Adviser Compliance Deficiencies,” which was published by NYU School of Law's Compliance & Enforcement Blog. The article presented key takeaways from the OCIE’s recently-published Risk Alert which provided an overview of registered investment adviser compliance issues related to Rule 206(4)-7 under the Investment Advisers Act of 1940. Among the Compliance Rule deficiencies the Risk Alert identified, included failures by advisers to devote adequate resources to their compliance programs, chief compliance officers who lacked sufficient authority within the adviser to develop and enforce appropriate policies and procedures, and insufficiencies pertaining to advisers’ annual compliance program reviews.
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