SEC’s OCIE Publishes Investment Adviser Branch Office Risk Alert

On November 9, 2020, the Office of Compliance Inspections and Examinations (“OCIE”) of the US Securities and Exchange Commission (“SEC”) published a risk alert discussing its observations from a series of examinations that focused on SEC-registered investment advisers operating from numerous branch offices and with operations geographically dispersed from the adviser’s principal or main office. In this initiative, OCIE staff assessed, among other things, the advisers’ compliance and supervisory practices relating to advisory personnel working within the advisers’ branch offices. The following Legal Update provides a summary of OCIE’s observed deficiencies outlined in the risk alert, followed by a discussion of observed practices that seek to mitigate compliance risks.