The Securities and Exchange Commission has a launched a multi-branch advisor initiative targeting the “unique risks and challenges” for advisors operating through branch offices geographically separate from their principal place of business.
Challenges in the branch office model specifically include designing and implementing compliance programs, as well as supervising people and processes in branch offices, the SEC’s Office of Compliance Inspections and Examinations states in its Dec. 12 Risk Alert.
OCIE’s “Multi-Branch Adviser Initiative” will focus on compliance supervision, the role and empowerment of compliance personnel, and how policies and procedures are implemented. OCIE staff will also review investment recommendation oversight, conflicts of interest, and allocation of investment opportunities. The process multi-branch firms use regarding oversight and supervision of branch office activities will also be reviewed.