These examinations focused on whether the examined investment advisers had adopted and implemented reasonably designed written policies and procedures and implemented investment advice in an appropriate manner. As a summary, the staff reviewed firms’ main and branch office practices for:
(1) compliance with various rules under the Investment Advisers Act of 1940, including Rule 204A-1 and Rule 206(4)-2;
(2) the adherence by branch offices to comply with disclosures and agreements with clients relating to fees and expenses;
(3) the oversight of investment recommendations, and ensuring that those recommendations are suitable and consistent with disclosures to clients;
(4) management and disclosure of conflicts of interest; and
(5) allocation of investment opportunities.