John P. Falco, a partner in the Financial Services Practice Group of Pepper Hamilton, was quoted in the February 11, 2019 ACA Insight article, "OCIE Exam Priorities List is a Tool, Not a Compliance Blueprint."
"An investment adviser is a fiduciary that owes its clients a duty of care," said Pepper Hamilton partner John Falco. "Doing the bare minimum in terms of compliance or just focusing on OCIE priorities may not meet that duty. The areas covered in a firm’s compliance review and testing need to be suited to the firm’s business, its client base and the firm’s identified risks."
Focusing only on the exam priorities, he said, "is a recipe for complacency, and you leave yourself open for compliance issues in areas not identified by the OCIE’s priorities."
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