In September 2017, the OCIE issued a Risk Alert notifying advisors of the most common deficiencies related to the Advertising Rule. Interestingly, all the deficiencies identified involved misleading performance advertising. The takeaways from the Risk Alert are detailed below. Misleading Performance Results. The Staff observed advisers that presented performance results without deducting advisory fees. The…

Over the past few months several ICSGroup clients have had their very first SEC examination. We’ve noticed some noteworthy trends in the types of issues that are of most concern to regulators. Being aware of these issues will enable you to be more prepared for the inevitable SEC exam and may help you avoid being…

On February 7, 2017, the Securities and Exchange Commission (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”) released a risk alert identifying the five compliance areas most commonly cited in deficiency letters sent to SEC-registered investment advisers (“RIA”). The risk alert focuses on deficiency letters from more than 1,000 RIA audits conducted over the past two years. This…

The SEC’s Office of Compliance Inspections and Examinations has released its Exam Priorities for 2016. Exam priorities and initiatives launched in 2015 will continue to hold the spotlight in 2016 as new risk-based initiatives address systemic issues. Each regulatory topic can be broken down into the following four categories: (1) protecting the individual investor; (2)…

One of the SEC’s FY 2016 top priorities is to examine approximately 14% of all registered investment advisers. Doing so will require hiring an additional 225 examiners. To streamline its efforts, the SEC will be focusing on examining advisory firms that have never been examined. In FY 2014, the SEC examined 10% of approximately 11,500…

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