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SEC Launches Exam Initiative Targeting Advisers with Multiple Branches

The SEC’s Office of Compliance Inspections and Examinations issued a Risk Alert  announcing an initiative to examine investment advisers operating out of multiple branch offices. OCIE noted that the use of a branch office model “can pose unique risks and challenges to advisers, particularly in the design and implementation of a compliance program and the supervision of people and processes in branch offices.”  The examinations will focus on advisers’ compliance programs; oversight of investment advisory services provided at branch offices; calculation of fees and expenses; controls over advertisements; supervision and review of investment recommendations; and identification, management, and disclosure of conflicts of interest, among other areas. 

 
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