Clifford Chance

Coronavirus: Operational and Regulatory Risk-Off Strategies for SEC-Registered Investment Advisers

March 24, 2020

As the impact from the spread of the novel coronavirus continues to affect the global economy and disrupt business operations, investment advisers should be focusing on the short- and long-term operational and regulatory risks to their firms. While the U.S. Securities and Exchange Commission has acknowledged the challenges that advisers confront under the present circumstances, the agency has also reminded advisers to continuously evaluate their obligations under the Federal securities laws, including their fiduciary duty to clients. Advisers must also ensure that business continuity and operational resilience planning can guarantee the adviser's ability to meet client obligations and expectations. This briefing discusses key operational and regulatory risks to advisers presented by the ongoing COVID-19 emergency and offers suggestions on how advisers should address these risks.

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