The SEC’s Office of Compliance Inspections and Examinations, or OCIE, has published a list of the five compliance topics most frequently identified in deficiency letters that are sent to SEC-registered investment advisers. Within each of these topics, OCIE includes a few examples of typical deficiencies to highlight the risks and issues that examiners commonly identify. The five compliance topics addressed in this Risk Alert are deficiencies or weaknesses involving:

• Rule 206(4)-7, which is referred to as the Compliance Rule. under the Investment Advisers Act of 1940, or the Advisers Act;
• Required regulatory filings;
• Rule 206(4)-2 under the Advisers Act, which is referred to as the Custody Rule;
• Rule 204A-1 under the Advisers Act, which is referred to as the Code of Ethics Rule; and
• Rule 204-2 under the Advisers Act, which is referred to as the Books and Records Rule.