Investment Adviser Compliance and Reporting: Latest Developments and OCIE Exam Hot Buttons

Navigating Form ADV Amendments and Preparing for OCIE Examination Priorities, Including New Scrutiny on ERAs

Recording of a 90-minute CLE webinar with Q&A


Conducted on Wednesday, February 17, 2016

Recorded event now available

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Program Materials

This CLE webinar will discuss the latest developments in Investment Adviser Compliance and Reporting. The program will cover upcoming 2016 Form ADV Filings and the SEC’s proposed rules to expand ADV reporting responsibilities. The program will also cover OCIE examination priorities, including its new and unprecedented intent to include Exempt Reporting Advisers (ERAs) in its compliance exams.

Description

Advisers with a Dec. 31, 2015, fiscal year end must file their annual Form ADV amendments by March 30, 2016. The SEC’s Proposed Rules to expand information reported on Form ADV is expected to be finalized in the first part of 2016. As investment advisers complete required filings in 1Q 2016, it is an opportunity to review current systems and gaps in information gathering and reporting that exist based on the requirements of the proposed rules.

In January 2016, OCIE announced its examination priorities for 2016. In November 2015, the Director of the OCIE stated the agency is now routinely examining ERAs to venture capital funds and certain other private funds. This is a marked departure from past OCIE practice and could affect over 3,000 ERAs.

OCIE has taken notice of the trend in the investment management industry of outsourcing compliance activities to consultants or law firms and conducted about 20 examinations as part of its Outsourced CCO Initiative. The OCIE’s report and observations from these exams is a critical read for practitioners representing investment advisers.

Listen as our authoritative panel of investment management practitioners and compliance consultants covers latest developments in investment adviser compliance and reporting. The panel will discuss 2016 Form ADV filings as well as the SEC’s proposed rules to expand ADV reporting responsibilities. The program will also cover OCIE examination hot buttons, including fees, expense allocations, and Regulation D compliance and its new intent to include ERAs in its compliance exams.

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Outline

  1. Annual compliance reviews
  2. Current OCIE hot buttons for RIAs and ERAs
    1. Conflicts - valuation, allocation of portfolio transactions and expenses
    2. Recent SEC enforcement cases
    3. New OCIE examination initiative for Exempt Investment Advisers
    4. Outsourcing compliance responsibilities
    5. Cybersecurity compliance and controls
  3. Form ADV Amendments for 2016
    1. SEC’s proposed rules to expand information reported on Form ADV, including additional reporting requirements with respect to Separately Managed Accounts and codification of filing adviser/relying adviser regime

Benefits

The panel will review these and other key issues:

  • What are the key elements of the SEC’s proposed rules expanding ADV reporting and what steps should investment advisers take now in anticipation of final rules in 2016?
  • What observations has OCIE staff made regarding exams conducted pursuant to its Outsourced CCO Initiative?
  • Where is the SEC expected to focus its inspection of registered investment advisers and exempt reporting advisers?

Faculty

Cary J. Meer
Cary J. Meer

Partner
K&L Gates

Ms. Meer structures private funds as limited liability companies, limited partnerships, offshore corporations, common...  |  Read More

Beth Clark
Beth Clark

Of Counsel
K&L Gates

Ms. Clark concentrates her practice in the investment management and securities areas where she advises...  |  Read More

Alan K. Halfenger
Alan K. Halfenger
Partner
ACA Compliance Group

Mr. Halfenger has over 20 years of global compliance experience. Prior to joining his current firm he served as...  |  Read More

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