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Richey May Technology Solutions provides the full spectrum of transformative solutions for your business.

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Specializing in Mergers & Acquisitions, management reporting and operational improvements for you business.

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Technology Solutions

Richey May Technology Solutions provides the full spectrum of transformative solutions for your business.

Learn More

Business Advisory

Specializing in Mergers & Acquisitions, management reporting and operational improvements for you business.

Learn More

Contact Us

Richey May Headquarters
9605 S. Kingston Ct. Suite 200
Englewood, CO 80112
Directions
303-721-6232

Question or comments?  Click here to fill out our inquiry form.

Technology Solutions

 

Richey May Technology Solutions provides the full spectrum of transformative solutions for your business.

Learn More

Business Advisory

Specializing in Mergers & Acquisitions, management reporting and operational improvements for you business.

Learn More

Technology Solutions

 

Richey May Technology Solutions provides the full spectrum of transformative solutions for your business.

Learn More

Business Advisory

Specializing in Mergers & Acquisitions, management reporting and operational improvements for you business.

Learn More

Contact Us

Richey May Headquarters
9605 S. Kingston Ct. Suite 200
Englewood, CO 80112
Directions
303-721-6232

Question or comments?  Click here to fill out our inquiry form.

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Richey May Headquarters
9605 S. Kingston Ct. Suite 200
Englewood, CO 80112
Directions
303-721-6232
Alternative Investment

Risk Alert from the OCIE

Articles by: Richey May, Sep 23, 2019

September 2019

The OCIE recently published a Risk Alert that provides an overview of the most common compliance issues identified by the OCIE in examinations of advisers related to Investment Adviser Principal and Agency Cross Trading Compliance Issues. The Richey May Alternative Investments experts have gone through the updates and summarized the key takeaways that impact pooled investment vehicles.  

 

Investment advisers need to review their written policies and procedures to ensure that such policies comply with the principal trading and agency cross transaction provisions of the Advisers Act and the rules thereunder, especially the following: 

  • Investment advisers need to obtain prior permission from the pooled investment vehicle before conducting major/significant trades with such pooled investment vehicles.  

 

  • Additionally, investment advisers need to disclose their significant ownership interests in the pooled investment vehicle when they affect trades between their clients and such owned pooled-investment vehicle. 

 

If you have any questions about how this Risk Alert impacts your pooled investment vehicle, or about the alternative investment services Richey May provides to the industry, please contact Stephen Vlasak