OCIE Publishes Risk Alert Regarding Cash Solicitation Rule

OCIE Publishes Risk Alert Regarding Cash Solicitation Rule


By: Jessica Forbes, Stacey Song, Joanna D. Rosenberg

On October 31, 2018, the Office of Compliance Inspections and Examinations (“OCIE”) published a National Exam Program Risk Alert (the “Risk Alert”) on the most frequent compliance issues relating to Rule 206(4)-3 (the “Cash Solicitation Rule”) under the Investment Advisers Act of 1940. In the Risk Alert, OCIE identified four areas of deficiencies. The Risk Alert does not change the position of the staff of the Securities and Exchange Commission set forth in the 2008 no-action letter regarding the application of the Cash Solicitation Rule to investors in pooled investment vehicles.

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