ILPA Members:
On June 23, 2020, the U.S. Securities & Exchange Commission (“SEC”) released a Risk Alert on June 23rd that provided an overview of compliance issues observed by the SEC’s Office of Compliance Inspections and Examinations (OCIE) in their examinations of registered advisers that manage private funds. The SEC has not released a similar risk alert in a number of years.
The Risk Alert discusses three general areas of deficiencies that the OCIE has observed in their examinations: conflicts of interest, fees and expenses, and policies and procedures relating to the use of material non-public information. A more detailed analysis of the types of deficiencies observed can be found in the attached overview that the ILPA team has put together, led by Brian Hoehn.