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  • January 22, 2018
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    Déjà Vu All Over Again, Version 2.0

    October 5, 2017

    Déjà Vu All Over Again, Version 2.0

    On Sept. 14, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert, “The Most Frequent Advertising Rule Compliance Issues Identified in OCIE Examinations of Investment Advisers.” I have read many deficiency letters from most of the SEC Regional Offices, and I think that in this Risk Alert, the SEC did identify the most common advertising deficiencies, probably over the last 30 years. Some of us remember when the SEC Division of Investment Management (“IM”), issued a no-action letter publicly available on Oct. 28, 1986 to Clover Capital Management.


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