SEC Alert: Most Frequent Best Execution Issues Cited in Adviser Exams
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The Office of Compliance Inspections and Examinations (“OCIE”) has issued a SEC alert1 to provide investment advisers, investors and other market participants with information concerning many of the most common deficiencies that the staff has cited in recent examinations of advisers’ compliance with their best execution obligations under the Advisers Act.
Most Frequent Best Execution Issues Cited in Adviser Exams
- Not performing best execution review;
- Not considering relevant factors during best execution review;
- Not seeking comparisons from other brokers;
- Disclosure issues;
- Soft dollar issues; and
- Weak policies and procedures.
“Advisers should reflect upon their practices, policies and procedures in light of their best execution obligations under the Investment Advisers Act of 1940 and make improvements in their adviser compliance programs.”2 3
Want to know if your Best Execution practices, policies and procedures meet the expectations of the SEC? Call Alaric Compliance today at 1-888-243-2448, or email email@example.com to learn how Alaric — voted Best Compliance Firm by Alt Credit Intelligence, an HFM Global Publication in 20184 — can help you manage your compliance challenges.