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August 2020

OCIE Risk Alert: Select COVID-19 Compliance Risks and Considerations for Broker-Dealers and Investment Advisers

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COVID Produces New Adviser Hybrid Business Model

For most registered investment advisers, business continuity implementation in the COVID era entails some element of an employee work from home arrangement. As investment advisers approach month seven of COVID business continuity implementation, it is prudent to consider the ramifications attendant to long term business continuity implementation.  Working from home is on the verge of becoming a quasi-permanent feature of investment adviser business models and therefore the SEC is directing advisers to evaluate compliance risk sets related to the remote work configuration.

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