Stout and Silver Regulatory Associates present a “compliance playbook” to navigating recent Office of Compliance Inspections and Examinations (“OCIE”) risk alerts in the COVID-era. The discussions are centered around areas related to valuation, forensic accounting of allocation of fees and expenses, assurance of proper adherence to fund governing documents and overall risk disclosures to investors, and avoidance of the appearance of impropriety and fraud.

Panel:

• Justin Burchett, Managing Director, Stout
• Joel E. Cohen, Managing Director, Stout
• Larry Block, Managing Director, Counsel and Chief Compliance Officer, Island Capital Group LLC
• Jeremy Vaughan, Senior Vice President of Compliance, Starwood Property Trust, Inc.
• Fizza Khan, CEO, Silver Regulatory Associates (Moderator)

Part 1: Lessons Learned from the OCIE's Recent Examination Findings and Best Practices in an Era of Uncertainty

Following the OCIE Risk Alert issued on June 23, 2020 regarding “observations of investment advisers managing private funds,” this discussion offers a deep dive into the OCIE’s findings and practical guidance for firms to proactively detect any potential threats of fraudulent activity or other deficiencies in advance of a routine exam.

Part 2: Meeting Heightened Regulator Expectations

As the SEC continues to sharpen its lens on potential heightened risks of misconduct due to COVID-19 and increased market volatility, this second webinar in the series provides a brief overview of the OCIE’s Risk Alert, “Select COVID-19 Compliance Risks and Considerations for Broker-Dealers and Investment Advisers” issued on August 12, 2020, as well as firsthand experiences with recent SEC examinations.

Part 3: Is Your Firm Under the Lens of the SEC?

Following the OCIE’s most recently issued Risk Alerts – OCIE Observations: Investment Adviser Compliance Programs (11/19/20) and Observations from OCIE Examinations of Investment Advisers: Supervision, Compliance and Multiple Branch Offices (11/9/20) – it is clear the SEC is laser focused on investment managers’ compliance programs, has ramped up examinations, and is continuing to bring forth a high frequency of enforcement actions against registered investment advisers. During our Part 3 presentation, we review important highlights from the most recent OCIE risk alerts, consider how a new administration may impact the regulatory climate for investment managers, and provide practical guidance and a checklist for how to meet regulatory guidelines as we head into 2021.