Not long after announcing its exam priorities for 2017, The SEC’s Office of Compliance Inspections and Examinations provided a list of the five compliance topics most frequently identified in deficiency letters that were sent to SEC-registered investment advisers.
The five areas are:
(1) Rule 206(4)-7 (the Compliance Rule);
(2) Required regulatory filings (like Form ADV accuracy and timeliness);
(3) Rule 206(4)-2 (the Custody Rule);
(4) Rule 204A-1 (the Code of Ethics Rule); and
(5) Rule 204-2 under the Advisers Act (the Books and Records Rule).