December 2020

As 2020 winds to a close, the regulators are intent on making sure their voices are heard. From the SEC to the states, regulatory guidance is plentiful. The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) issued three Risk Alerts in just the past 45 days. The Multi-Branch Initiative Alert was issued in early November and focused on registered investment advisers operating from branch offices and/or with operations geographically dispersed from the adviser’s principal office. The second November Alert focused on adviser compliance programs and the capabilities of the examined firms to implement their compliance programs effectively and consistently.  In December, OCIE snuck in yet another Risk Alert related to large trader compliance under Rule 13h-1.