September 2019
The OCIE recently published a Risk Alert that provides an overview of the most common compliance issues identified by the OCIE in examinations of advisers related to Investment Adviser Principal and Agency Cross Trading Compliance Issues. The Richey May Alternative Investments experts have gone through the updates and summarized the key takeaways that impact pooled investment vehicles.
Investment advisers need to review their written policies and procedures to ensure that such policies comply with the principal trading and agency cross transaction provisions of the Advisers Act and the rules thereunder, especially the following:
- Investment advisers need to obtain prior permission from the pooled investment vehicle before conducting major/significant trades with such pooled investment vehicles.
- Additionally, investment advisers need to disclose their significant ownership interests in the pooled investment vehicle when they affect trades between their clients and such owned pooled-investment vehicle.
If you have any questions about how this Risk Alert impacts your pooled investment vehicle, or about the alternative investment services Richey May provides to the industry, please contact Stephen Vlasak.
