During the 2020 fiscal year, the SEC Office of Compliance Inspections and Examinations (OCIE) conducted more than 2,950 examinations, including 15% of all registered investment advisors. Those numbers come from Pete Driscoll, director of the OCIE, who announced them as part of a recent speech.
We successfully began initiatives to review compliance with Regulation Best Interest and Form CRS and to assess registered advisers’ and investment companies’ preparedness for the transition away from LIBOR,” noted Driscoll.
He explained that OCIE “has continued to conduct examinations off-site through correspondence.” The agency “engaged in outreach and other efforts with many investment advisers and investment company complexes to assess the impacts of Covid-19 and to gather information, including challenges with operational resiliency and fund liquidity.”
As it seems, Business Continuity Plans (BCPs) proved beneficial to firms overall. “We found that the majority of firms we met with had business continuity plans and had activated them. A small percentage of the hundreds of firms we virtually met with actually had pandemic specific plans that were in existence before the Covid-19 pandemic, but I think most were fortunate that BCPs generally were beneficial in addressing the impact of the pandemic,” commented Driscoll.
He also added, “critical areas for operations were typically covered in the BCPs. We saw BCPs that provide for personnel to work in separate remote sites, succession plans that address the death or lengthy incapacitation of key personnel and contingency plans for when other essential personnel are unable to work for extended periods.”
