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SEC Finds Deficiencies in Disclosing Conflicts of Interest and MNPI

The Office of Compliance Inspections and Examinations (OCIE) of the Securities and Exchange Commission (SEC) recently published the Risk Alert Observations from Examinations of Investment Advisers Managing Private Funds. 

 

The Risk Alert covers three general areas of deficiencies that the OCIE has identified in examinations of private fund advisers: conflicts of interest, fees and expenses, and policies and procedures relating to material non-public information (MNPI). The alert outlines concerns and compliance issues observed during examinations of registered investment advisers that manage private equity funds or hedge funds—and serves notice that the SEC will continue to put a high priority on customer well-being.

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Three Steps to an Effective COI Compliance Program

Chances are your organization has developed a conflict of interest (COI) policy. But does it have an effective COI compliance program in place? Can you demonstrate it to regulators? If the answer is no to either of those questions, there are three things you need to do now to satisfy regulators that you take COI prevention seriously.  

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