In mid-November, the SEC published a lengthy Risk Alert highlighting its findings from recent examinations of a variety of advisers providing electronic investment advice ('Robo-advisers"). The Alert notes that almost every adviser examined by the SEC was cited for deficiencies. Notably such deficiencies included, (1) weak compliance programs, including policies, procedures, and testing; (2) deficient portfolio
management, including, but not limited to, an adviser’s fiduciary obligation to provide advice that is
in each client’s best interest; and (3) marketing/performance advertising, including misleading
statements and missing or inadequate disclosure. The Risk Alert provides guidance on the steps Robo-advisers can take to assure compliance. Please refer to the Risk Alert by clicking the headline to this summary.