OCIE’s 2019 Examination Priorities and 2018 Enforcement Actions: Practice Points for Advisers to Consider

The US Securities and Exchange Commission’s (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”) released its 2019 examination priorities on December 20, 2018. As was the case in prior years, OCIE’s 2019 examination priorities cover investment advisers and registered investment companies as well as market participants such as broker-dealers and transfer agents. This Legal Update gives an overview of the exam priorities for investments advisers, briefly describes certain key SEC enforcement actions brought in 2018 applicable to advisers and offers certain practice points that advisers may want to consider in response to those priorities and enforcement actions.