OCIE Publishes Risk Alert Regarding Principal and Agency Cross Trading

OCIE Publishes Risk Alert Regarding Principal and Agency Cross Trading


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

On September 4, 2019, the Office of Compliance Inspections and Examinations (“OCIE”) published a Risk Alert (the “Risk Alert”) listing examples of the most common compliance issues its staff identified relating to principal and agency cross transactions under Section 206(3) of the Investment Advisers Act of 1940, as amended (“Advisers Act”) and Rule 206(3)-2 thereunder. The Risk Alert serves as a reminder that this is an ongoing focus area for OCIE. We provide below a brief summary of the Risk Alert.

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