The Dangers of Recidivist Deficiencies and the SEC’s Compliance Program Initiative

December 2014

“In the past few years, the Securities and Exchange Commission (“SEC”) has taken a tougher stance against recidivist behavior by registered investment advisory firms (“RIAs”). Recidivism refers to occurrences where an RIA has not corrected deficiencies noted in previous regulatory examinations. The SEC is focusing on recidivist behavior through its “Compliance Program Initiative”, which seeks to identify firms who have failed to correct such deficiencies.

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