Investment Adviser Principal and Agency Cross Trading Compliance Issues

Topic: The purpose of this Risk Alert is to provide an overview of the most common compliance issues identified by OCIE related to principal trading and agency cross transactions under Section 206(3) of the Advisers Act, which were identified in examinations of investment.

Key takeaway: OCIE encourages advisers to review their written policies and procedures and the implementation of those policies and procedures to ensure that they are compliant with principal trading and agency cross transaction provisions of the Advisers Act and the rules thereunder.

View the Risk Alert: Investment Adviser Principal and Agency Cross Trading Compliance Issues (PDF)