Doug Cornelius on compliance for private equity real estate
The SEC’s Office of Compliance Inspections and Examination launched a lot info last week. It livestreamed a National Investment Adviser/Investment Company Compliance Outreach and published a Risk Alert on notable compliance issues identified by OCIE related to Rule 206(4)-7. Peter Driscoll, Director of OCIE, started off the program highlighting three words that should be applicable … Read more »
In 2017, the SEC’s Office of Compliance Inspections and Examination conducted exams of investment advisers that previously employed, or then currently employed, any individual with a history of disciplinary events. According to a just released Risk Alert, this was the Supervision Initiative. The initiative examined over 50 advisers, with a total of $50 billion in … Read more »
Earlier this month Norm Champ, Deputy Director, Office of Compliance Inspections and Examinations at the SEC, addressed the New York City Bar and gave a preview of what the SEC has in mind for private fund advisers. I thought this tied nicely with the speech given by Norm’s boss, Carlo V. di Florio, at PEI’s … Read more »
As part of the SEC’s new National Exam Program Overview, OCIE highlights six areas of focus for Investment Advisers: “[T]he Program has identified specific strategic areas on which to focus when examining firms…. In FY2012, focus areas include the following priorities, among others: Complex Entities. Staff will examine for the risks and practices associated with … Read more »
The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) mission is to protect investors through its nationwide examination and inspection program. Examiners in Washington DC and in the SEC’s 11 regional offices conduct examinations of the nation’s registered entities. Besides investment advisers, OCIE also examines broker-dealers, transfer agents, investment companies, the national securities exchanges, clearing … Read more »
For a registered investment adviser, it’s okay to have the SEC’s Office of Compliance Inspections and Examinations visit you. It’s a big problem if the enforcement division visit. OCIE will issue a deficiency letter asking you to fix any deficiencies it finds. If your noncompliance is serious or the examiners think investor funds are at … Read more »
SEC Inspector General H. David Kotz In the first Congressional hearing since the Madoff scandal broke in December, Mr. Kotz said his agency’s handling of the Madoff case may be a symptom of more widespread problems with how the agency handles its examinations and investigations. Kotz testified on the subject of “Assessing the Madoff Ponzi … Read more »
The SEC’s Office of Compliance Inspections and Examinations has published an letter to CEOs of SEC Registered Firms about the importance of compliance programs during this time of “financial and market turmoil.” December 2, 2008 Dear CEO of SEC-Registered Firm: During this time of financial and market turmoil, the Office of Compliance Inspections and Examinations … Read more »
The SEC’s Office of Compliance Inspections and Examinations has published its Core Initial Request for Information for Investment Adviser Examinations. The initial phase of an examination includes a review of the firm’s business and investment activities, its organizational affiliations and its corresponding compliance policies and procedures. The staff will request information and documents and speak … Read more »