Advisers and compliance officers alike were surprised when the SEC’s Office of Compliance and Examinations on Feb. 7 issued a Risk Alert listing the five most frequently identified deficiencies arising from over 1000 examinations over the last 2 years. The alert came without much explanation or introduction.

The surprises continued. Rather than focus on more substantive issues such as breach of fiduciary duty or fraud, OCIE fixed on more administrative compliance failures such as “off-the-shelf” compliance manuals, failed Code of Ethics reporting, and books and records weaknesses.

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