On November 9 2020, the Office of Compliance Inspections and Examinations (“OCIE”)  of the U.S. Securities and Exchange Commission (“SEC”) released a Risk Alert about its assessment of the compliance practices of SEC-registered investment advisers that have multiple branch offices. In its Risk Alert, the SEC noted that its Multi-Branch Initiative (“Initiative”) focused on investment advisers practices relating to compliance programs and supervision, with a particular focus on the Code of Ethics Rule, Custody Rule, and fiduciary obligations relating to fees, expenses, and advertising. The SEC also evaluated how supervised persons at branch locations provided investment advice, focusing on oversight of investment recommendations, management and disclosure of conflicts of interest, and allocation of investment opportunities.

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