On July 23, the Securities and Exchange Commission (SEC) Office of Compliance Inspections and Examinations (OCIE) published a Risk Alert on its "Observations from Examinations of Investment Advisers: Compliance, Supervision, and Disclosure of Conflicts of Interest." The purpose of this Risk Alert is to raise awareness of certain compliance issues that OCIE observed by sharing the Staff's observations from these examinations. The Risk Alert provides a good summary of the Staff's observations across a broad range of compliance topics, but emphasized its specific observations relating to employees or prospective employees with disciplinary histories. As stated by the Staff: "the key takeaway is that OCIE encourages advisers, when designing and implementing their compliance and supervision frameworks, to consider the risks presented by hiring and employing supervised persons with disciplinary histories and adopt policies and procedures to address those risks." Risk Alert.
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