OCIE Best Execution Risk Alert

On July 11, 2018, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert focusing on the most common deficiencies relating to best execution found by the SEC staff in recent examinations of investment advisers. The Risk Alert provides a snapshot of OCIE’s expectations regarding a fund manager’s best execution policies and procedures. In this article, partner Marc Elovitz and former Schulte lawyer Brian Daly discuss the Risk Alert and its implications for private fund managers.