Risk Alert Offers Insight on Exams of Newly Registered Advisers

Newly registered advisers have been an area of focus for the SEC Division of Examinations (Division) for each of the past ten years. A recent risk alert (Risk Alert) offers insight into what Division staff typically look for in their first examination of such advisers. The number of SEC-registered investment advisers has grown by more than 20% in the past five years, according to the Risk Alert. Those newly registered advisers may face unique compliance risks. Division staff use their examinations of those advisers as an “opportunity for engagement” with them. This article parses the Risk Alert, including the information the Division staff request and the areas of concern they have been finding in recent examinations of new registrants. See “Key Compliance Issues for Advisers and Funds Arising From the SEC’s 2022 Exam Priorities (Part One of Two)” (Jan. 19, 2023); and “Private Funds Top the SEC’s 2022 Exam Priorities” (Jun. 9, 2022).

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