SEC Exam Staff Issues Second ComplianceAlert

On July 22, the Securities and Exchange Commission’s (SEC’s) Office of Compliance, Inspections, and Examinations (OCIE) issued a ComplianceAlert, the second in a planned series of periodic updates that will summarize select areas of operational deficiency that SEC examiners have found during examinations of broker-dealers, investment advisers, investment companies, transfer agents, and other types of registered firms. Legal and compliance departments at such firms can use the ComplianceAlert to help identify those deficiencies that the SEC staff has noted in the past and that may need to be addressed. In addition, the ComplianceAlert suggests a number of practices that the OCIE found exemplary, which may merit implementation at other firms. Finally, from an enforcement perspective, the ComplianceAlert may be an indication of emerging compliance issues that the OCIE has chosen to address informally at this stage that may serve as the basis for enforcement referrals in the future.

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