meet the clients’ investment objectives; and are consistent with the investment principles and strategies that were disclosed by the manager to the adviser (as set forth in various documents, such as advisory disclosure documents, private offering memoranda, prospectuses, or other offering materials provided by the manager). The Risk Alert contains OCIE’s observations on industry practices, the industry’s compliance with the Advisers Act with respect to:
- compliance programs; and
- code of ethics.
Among OCIE’s findings were:
- Advisers are seeking more and broader information and data directly from managers of alternative investments;
- Advisers are utilizing third parties to supplement analyses and validate information regarding alternative investments;
- Advisers are performing additional quantitative analyses and risk measures on the alternative investments and their managers; and
- Advisers are enhancing and expanding their due diligence processes and focus areas.
Reference: Due Diligence on Alternative Investments
Subject: Investment Advice
How To: Providing Investment Advice