Enforcement Actions

The links below provide insight into past SEC enforcement actions and most frequent compliance deficiencies noted by the SEC's Office of Compliance Inspections and Examinations. A review of these regulatory actions relative to an adviser's compliance program is a great way to identify and remedy policy or procedural gaps. The SEC continues its regulatory focus on issuer reporting and disclosure, with enforcement actions representing approximately 18% of total enforcement activity during the first half of 2017, an increase of approximately 11% from fiscal year 2016.*

*Data provided by David F. Marcus and Sara E. Gilley,

Cornerstone Research, May 7, 2017

2016 SEC ENFORCEMENT ACTIONS

Click here for the SEC's press release on enforcement actions related to financial reporting misconduct by investment advisers, investment companies and their gatekeepers. The press release covers the SEC's fiscal year ended September 30, 2016.

Click here for a summary of 2016 SEC enforcement actions against investment advisers. The link is a post by Jonathan N. Eisenberg, K&L Gates LLP, on Monday, December 19, 2016 to the Harvard Law Forum on Corporate Governance and Financial Regulation.

5 MOST FREQUENT COMPLIANCE TOPICS

IDENTIFIED BY OCIE EXAMINATIONS

Click here for the OCIE's February 2017 Risk Alert of the five most common compliance topics identified in deficiency letters issued over the past two years. The Risk Alert addresses deficiencies identified in the following categories:

The Compliance Rule (Rule 206(4)-7)
Regulatory Filings
Custody Rule (Rule 206(4)-2)
Code of Ethics (Rule 204A-1)
Books and Records (Rule 204(2))