ARTICLE · 18 JULY 2018

SEC Issues Risk Alert On Best Execution

Duff and Phelps

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After analyzing deficiency letters from over 1,500 investment adviser examinations, the SEC's Office of Compliance Inspections and Examinations released a risk alert regarding the most common deficiencies...

United StatesCorporate/Commercial Law

Kathleen Malone

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After analyzing deficiency letters from over 1,500 investment adviser examinations, the SEC's Office of Compliance Inspections and Examinations ("OCIE") released a risk alert regarding the most common deficiencies related to best execution.

Some examples of the most common deficiencies identified by OCIE included:

Not performing best execution reviews
Not considering materially relevant factors during best execution reviews
Not seeking comparisons from other broker-dealers
Not fully disclosing best execution practices
Not disclosing soft dollars arrangements
Not properly administering mixed use allocations
Inadequate policies and procedures relating to best execution

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