The SEC charged nine registered investment advisers with violating the Marketing Rule by disseminating advertisements […]
October 19, 2023
What: The Securities and Exchange Commission (SEC) announced its examination priorities for fiscal year 2024.
Who: Priorities for Broker-Dealers, Investment Advisers, Investment Companies, SROs, Clearing Agencies, and Other Market Participants (Municipal Advisors, Security-Based Swap Dealers, and Transfer Agents)
When: October 16, 2023. Although typically provided in Q1 of the same calendar year, the SEC is re-aligning its publication of examination priorities with the beginning of its fiscal year.
Why: The SEC prioritizes examination of certain practices, products, and services that it believes present potentially heightened risks to investors or the integrity of the U.S. capital markets.
How: In addition to focus areas for specific market participants, the SEC highlighted four areas applicable across the multiple participants: 1) Information Security and Operational Resiliency, 2) Crypto Assets and Emerging Financial Technology, 3) Regulation Systems Compliance and Integrity, and 4) Anti-Money Laundering and OFAC Sanctions.
Why it matters: The SEC has explained that it will allocate significant resources to the 2024 examination priorities. It is worth noting that the multiple participant topics noted above were similarly identified in the prior year’s priorities, which means that participants have now had two publication cycles of notice from the SEC regarding the importance of addressing these matters. As we close out 2023, firms should thoughtfully evaluate their compliance programs in light of the recent priorities to ensure they are particularly responsive to the SEC’s focus areas.
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Contact Mitch Avnet for further details: (646)346-2468 | mavnet@compliance-risk.com