The U.S. Securities and Exchange Commission’s (the “SEC”) Office of Compliance Inspections (“OCIE”) recently issued two separate risk alerts describing certain compliance and regulatory risks, considerations, deficiencies and issues applicable to SEC-registered investment advisers (“Advisers”) that have recently been observed or identified by OCIE. In particular, these risk alerts highlight (i) various common compliance issues, considerations, issues and deficiencies relating to conflicts of interest, fees and expenses, and policies and procedures relating to material, non-public information, and (ii) select COVID-19-related compliance risks, considerations, observations and recommendations. Advisers are encouraged to carefully review and consider these risk alerts and their current practices, policies and procedures and take any necessary or appropriate steps or measures or actions to address the issues outlined therein.
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