Description:
A one-hour panel discussion on the SEC’s rule issued in August 2023 that requires that all advisers registered with the Commission, including those that do not advise private funds, document in writing the annual review of their compliance policies and procedures. The annual compliance review has long been a requirement for registered investment advisors but there has not before been a rule expressly stating that review must be documented. The SEC has issued some guidance in the past as to what the annual review should include and brought some settled enforcement actions finding poor or non-existent annual reviews. This new rule, in an amendment to Investment Advisers Act rule 206(4)-7, adds to that guidance, as well as the risk that the Examinations Staff will assess whether written reports follow that guidance.

Who Should Attend: compliance officers of registered investment advisers and lawyers who advise them