The Division of Examinations (the Division) (formerly known as the Office of Compliance Inspections and Examinations, or OCIE) of the U.S. Securities and Exchange Commission (SEC) released its annual
Continue Reading 2021 SEC Examination Priorities for Securities Industry Registrants

The Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission (SEC) released its annual list of 2020 Examination Priorities on Jan. 7, 2020. Many of
Continue Reading 2020 SEC Exam Priorities for Securities Industry Registrants

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On Dec. 20, 2018, the Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission
Continue Reading SEC’s Office of Compliance Inspections and Examinations Releases 2019 Examination Priorities

On Jan. 12, 2017, the Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission (SEC) issued its annual Examinations Priorities for 2017 (Exam Priorities), which
Continue Reading SEC’s Office of Compliance Inspections and Examinations Releases Annual Examination Priorities

On July 13, 2016, the SEC’s Office of Compliance Inspections and Examinations (OCIE) announced its 2016 Share Class Initiative (the Initiative). The Initiative is focused on addressing the perceived risk
Continue Reading SEC Share Class Sweep of Registered Investment Advisers Appears to be Underway

Earlier this week, the Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission (SEC) issued a new Risk Alert (available here) related to the use of outsourced chief compliance officers (CCOs) by SEC-registered investment advisers and investment companies (Registrants). The Risk Alert shares staff observations of Registrants who outsource their CCO functions to unaffiliated third-parties resulting from nearly 20 examinations under OCIE’s Outsourced CCO Initiative. The Risk Alert identified a number of key concepts that should be considered by Registrants.

First, Registrants with outsourced CCOs should review their business practices in light of the risks highlighted by the staff and the Registrant’s responsibilities under applicable compliance rules. The Risk Alert emphasizes that Registrants not only must assure that outside CCOs have the requisite knowledge and experience to carry out the responsibilities of a CCO, they should also have the authority and access to the organization needed to accomplish their duties.
Continue Reading OCIE Issues Risk Alert on Use of Outsourced Chief Compliance Officers

Two weeks ago, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued its newest guidance on the subject of cybersecurity in the form of a new National Exam Program (NEP) Risk Alert, issued Sept. 15. In addition to the matters discussed below, the Risk Alert contains links to several earlier Commission and OCIE materials, including to the March 2014 SEC Cybersecurity roundtable, past NEP cybersecurity-related releases, and the 2015 SEC examination priorities.

With the purpose of “[providing] additional information on the areas of focus for OCIE’s second round of cybersecurity examinations” and in addition to informing industry participants that testing and assessing the implementation of cybersecurity procedures and controls will characterize the next phase of exams, the Risk Alert identifies six key areas of focus for OCIE: (1) governance and risk assessment; (2) access rights and controls; (3) data loss prevention; (4) vendor management; (5) training; and (6) incident response. The Risk Alert also provides a sample document request, which regulated entities may use in assessing their cybersecurity programs.


Continue Reading OCIE Issues New Cybersecurity Risk