SEC Risk Alert Focuses on Multi‑Branch Investment Advisers

The SEC’s Division of Examinations (Division) – formerly known as the Office of Compliance Inspections and Examinations, or OCIE – recently issued a risk alert on observations from examinations of investment advisers with multiple branch offices (Risk Alert). The Risk Alert presents the key findings from the Division’s multi-branch adviser examination initiative, focusing on compliance and supervision practices; controls over investment recommendations; disclosure of conflicts of interest; and trading issues. The Risk Alert also highlights the effective practices that multi-branch advisers used in their compliance programs. This article distills the Division’s principal findings and recommendations. See our coverage of SEC risk alerts on the coronavirus pandemic; private fund managers; the transition from LIBOR; Regulation Best Interest and Form CRS; electronic messaging; the cash solicitation rule; best execution; fees and expenses; the advertising rule; compliance topics; custody; cybersecurity; business continuity and disaster recovery plans; and social media.

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