Category Archives: Newly-Registered Investment Advisers
 

Common Deficiencies of Newly Registered Investment Advisers

April 14, 2023

In a recent Risk Alert by U.S. Securities and Exchange Commission (“SEC”), the Examination Division identified several common issues among newly registered investment advisers (also referred as RIAs): (1) compliance policies and procedures; (2) disclosures and filings; and (3) marketingAlthough these findings are based upon examinations of federally registered investment advisers, it’s our experience that newly state registered firms have similar issues.

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SEC to Conduct Presence Exams for Newly Registered Investment Advisers

March 06, 2013

In a release issued by the SEC on October 9, 2012, the U.S. Securities and Exchange Commission (“SEC”) announced “Presence Exams” for certain newly-registered investment advisers (investment advisers registered after July 21, 2011). The presence exams are to be conducted by SEC’s Office of Compliance Inspections and Examinations (“OCIE”) through the new National Exam Program (“NEP”) initiative. These “focused, risk-based examinations” will be conducted of investment advisers to private funds registered with the SEC.  These Presence Exams will take place over a two-year period and have three primary phases:

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