Focus Areas for Private Fund Managers From OCIE’s 2020 Exam Priorities

The SEC’s Office of Compliance Inspections and Examinations (OCIE) recently published its 2020 Examination Priorities (Priorities), which include several areas for which private fund managers should ensure they have robust policies and procedures in place. New to the Priorities are specific risk areas targeting private fund managers, as well as other areas generally applicable to those managers. In a guest article, Jane Jarcho, special advisor to Promontory Financial Group (Promontory) and former Deputy Director of OCIE, and Sarah Curran, director of Promontory and former Exam Manager in OCIE’s Private Fund Unit, summarize the above topics and include insights regarding documents that an exam team might request and potential individuals who are likely to be interviewed on those topics as part of an OCIE exam, as well as ways a chief compliance officer can prepare for an OCIE exam in one of the priority areas. For additional commentary from Jarcho, see “The Relationship Between OCIE and Enforcement” (Mar. 28, 2019); and “OCIE’s National Exam Program and Annual Priorities” (Apr. 4, 2019).

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