On June 23, 2020, the Office of Compliance Inspections and Examinations (“OCIE”) of the Securities and Exchange Commission (“SEC”) published a risk alert (“Risk Alert”) providing an overview of certain compliance issues observed by OCIE in examinations of registered investment advisers that manage private equity funds or hedge funds (“private fund advisers”). The Risk Alert discusses three general areas of deficiencies identified by OCIE: (1) conflicts of interest, (2) fees and expenses and (3) policies and procedures relating to material non-public information (“MNPI”). Many of the deficiencies identified are recurring themes that have been the subject of past enforcement actions and prior risk alerts. To this end, the Risk Alert provides a valuable compilation of key areas that private fund advisers should vigilantly monitor to ensure adequate disclosure, as well as compliance with their internal policies and procedures.
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