Alert February 25, 2014

SEC Examination Staff Launches Never-Before Examined Adviser Initiative

The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) sent a letter to advisers that have not yet been examined by the SEC as part of an initiative to examine a significant percentage of them, with a focus on those that have been registered with the SEC for three or more years.  This initiative, which excludes advisers subject to the Presence Exam initiative for newly registered private fund advisers, is an element of the National Examination Program’s 2014 priorities, which were described in the January 21, 2014 Financial Services Alert.  The press release announcing the initiative notes that starting later this year, OCIE will invite SEC-registered investment advisers who have yet to be examined to attend regional meetings where they can learn more about the examination process.