RIC Risk Alert | Bernadette Murphy Insights
VIGILANT INSIGHTS
Introduction
The SEC recently released a Risk Alert focusing on frequent deficiencies found during their examinations of Registered Investment Companies (“RICs”).
They have found that many Funds have poor oversight, and their documentation practices are frequently sub-par.
Bernadette Murphy, MSL, one of Vigilant’s Managing Directors, was recently quoted in an Ignites article discussing the important implications from this alert.
Bernadette Murphy Insights
Board oversight is a major concern for the SEC, as indicated in this Risk Alert.
Documentation of oversight will be essential for surviving an SEC examination.
Policies and procedures, advertising, board decisions, disclosures, and valuation processes are just some of the examples of areas the SEC will want to evaluate.
Bernadette emphasizes that compliance professionals must assess the oversight processes of their boards to ensure that they are abiding by the application regulations and adequately documenting decisions made on behalf of the Funds they govern. In the past, where certain issues would have produced a deficiency letter, some of these issues now appear to be escalated to the level of enforcement.
Vigilant’s Conclusion
It is likely that the SEC considers this Risk Alert to be their fair warning that Funds should increase their focus on compliance.
When a thorough analysis of one’s compliance program is necessary, partnering with experienced compliance professionals can help alleviate the burden placed on your compliance staff. This allows your team to focus on their business goals. Allow us to help guide your program while helping limit any gaps in your policies and procedures.
To learn more about how we can help, schedule a call with Vigilant clicking the button below.