Pair of Risk Alerts Focuses on Issues Associated With Cross Trades, Principal Transactions and Wrap Fees

The SEC Division of Examinations recently issued a pair of risk alerts: one covering principal transactions and cross trades; and the other covering wrap fee programs. The alerts reflect the SEC’s continuing focus on the importance of robust compliance programs, clear disclosures to clients and advisers’ fulfilment of their fiduciary duties – notably identification and mitigation of conflicts of interest. This article analyzes the commonalities between the alerts and their implications for advisers, as well as the specific deficiencies identified in each alert. See “SEC Continues to Focus on Cross Trades and Principal Transactions” (Apr. 16, 2020); and “Pay to Play, Revenue Sharing and Wrap Fees Remain on the SEC’s Radar” (Apr. 20, 2017).

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