Division of Examinations’ 2021 Exam Priorities: Perennial Focus Areas for Private Fund Managers (Part Two of Two)

The SEC’s Division of Examinations recently released its 2021 Examination Priorities (Priorities). The Priorities identify a broad range of areas that are directly relevant to private fund managers. As a result, exams of private fund managers – and referrals from Examinations to the SEC’s Division of Enforcement – may increase. In a two-part guest series, Jane Jarcho, Sarah Curran and Drew Weilbacher from Promontory Financial Group summarize the topics discussed in the Priorities and include their expectations regarding specific areas of focus, documents that an exam team might request and potential individuals who are likely to be interviewed. This second article reviews perennial focus areas in private fund managers’ exams. The first article addressed new or emerging focus areas. See “Focus Areas for Private Fund Managers From OCIE’s 2020 Exam Priorities” (Feb. 27, 2020).

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