The Top Five "Gotcha" Deficiencies Plaguing Asset Managers And How To Avoid Them

Let's start with this caveat: as we all know, under the still-new Trump Administration, priorities may and are likely to change. Now that we got that off our chest, it is nevertheless not the time to sit back and wait. The SEC's Office of Compliance Inspections and Examinations (OCIE) has just given us a list of potholes that investment advisers keep falling into. 

The OCIE identified the top five deficiencies that it sees over and over when conducting investment adviser examinations. This is what you need to know and what you need to do to avoid these deficiencies.

Compliance Rules

• Use "off-the-shelf" compliance manuals at your own risk.  Yes, you can start with one. Too often, however, off-the-shelf manuals simply restate the rules, subjecting your firm to needless complexity or requirements that do not apply to your specific businesses and practices. Make sure your policies and procedures are properly tailored to your individual business practices—what you