OCIE Risk Alert on Advisers Act Advertising Rule Compliance Issues
Published: 15 September 2017
The U.S. Securities and Exchange Commission’s Office of Compliance, Inspections and Examinations (OCIE) has issued a this Risk Alert which provides a list of compliance issues relating to Rule 206(4)-1 (the “Advertising Rule”) under the U.S. Investment Advisers Act of 1940, as amended.
OCIE has published this Risk Alert in order to “encourage advisers to assess the full scope of their advertisements and consider whether those advertisements are consistent with the Advertising Rule, the prohibitions of Section 206, and their fiduciary duties, and review the adequacy and effectiveness of their compliance programs”.
The compliance issues identified in the Risk Alert were the most frequently identified in deficiencies in recent OCIE examinations of SEC-registered investment advisers. If you have any questions in relation to this, please contact Jennifer Wood.