The Gift of Guidance
As an SEC examiner, we used to keep our playbook private. However, the OCIE now shares guidance through Risk Alerts and outreach engagements, giving us insight into the Division of Enforcement’s litigation releases. The Division of Investment Management helps create the framework for new rules through its adopting releases. This week, we’re considering amendments to advertising and solicitation rules and look forward to hearing from staff. While we appreciate these guidelines, it’s essential to use them continually to improve our policies and procedures. Recently, OCIE emphasized that CCOs need necessary resources and knowledge and recommended outsourcing an independent review to evaluate compliance programs. Checklists demonstrating reviews of SEC guidance releases are also helpful. An independent review fulfills compliance requirements, client demands and brings peace of mind.
