9d. IA/IC/PF - Outsourcing to Service Providers (Intermediate - OPEN)
Investment Advisers engage service providers to perform functions that benefit the Adviser and the clients. While certain service providers may not be deemed mission critical, others may have access to clients’ non-public information and be critical to the functions of the Adviser. The SEC Division of Examinations has made advisers’ selection and monitoring of such third parties a focus for fiscal year 2024. The Division intends to focus on the policies, procedures, and ongoing due diligence Advisers perform to oversee these service providers. How a firm supervises their service providers will vary based on the type of service provider at issue and, if applicable, the kinds of services being outsourced. This session will explore best practices, discuss real life scenarios, appropriate supervisory actions, and how compliance can effectively conduct oversight.
This session is open to regulators but closed to members of the press.
Learning Objectives:
Identify ways to inventory service providers with MNPI and mitigate risks associated with use of third parties.
Analyze different methods used to oversee relationships with third parties.
Learn ways to identify opportunities to further develop your firm’s due diligence and monitoring programs.
Share best practices for documenting oversight and training tips for due diligence of service providers, including meetings, annual reviews, etc.
Analyze the SEC proposed rule related to outsourcing services and functions to service providers.
