OCIE’s 2019 Priorities Focus on Retail, But PE Managers Remain in Examiners’ Sights

9 January 2019
View Debevoise Update
Key takeaways:
  • While the 2019 OCIE examination priorities focus on protecting retail investors, private fund sponsors will continue to be a significant focus of OCIE in the coming year.
  • In particular, private fund sponsors should review recent SEC enforcement actions with an eye to update and review their disclosures concerning fees and expenses and ensure that costs are being calculated and allocated in accordance with such disclosures.
  • Private fund sponsors should also continue to evaluate and disclose their conflicts of interest, assess their cybersecurity and anti-money laundering programs, and consider risks associated with digital assets, including blockchain, cryptocurrency and tokens.