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SEC Risk Alert – Large Trader & Form 13H Obligations for Investment Advisers

December 29, 2020

On December 16 2020, the Office of Compliance Inspections and Examinations (“OCIE”) of the U.S. Securities and Exchange Commission (“SEC”) released a Risk Alert about its assessment of the compliance practices of SEC-registered investment advisers and broker dealers with regard to Rule 13h-1, which was adopted to help the SEC identify and obtain information on certain market participants (referred to as “Large Traders”) that conduct a substantial amount of trading activity as measured by volume or market value, in national market system (“NMS”) securities. In the Risk Alert, OCIE noted that some advisers and broker dealers it examined were unaware of the rule or its specific requirements and, consequently, is encouraging all SEC-registered investment advisers and broker-dealers to review and update their compliance policies and procedures, as needed, to ensure compliance with Rule 13h-1. Click here to read the SEC’s Risk Alert for Large Trader Obligations.

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