The SEC’s Division of Examinations (Division) previously issued a risk alert on notable compliance program issues its staff identified during examinations of private fund managers (Risk Alert). Among other issues, the Risk Alert details a lack of compliance resources; a dearth of autonomy and empowerment of CCOs; and a failure to adequately tailor and implement policies and procedures across an array of areas. Peter Driscoll, then-Director of the Division, emphasized the severity of those issues in remarks given the same day (Speech), which further explained the Division’s stance on certain key issues. Taken together, the Risk Alert and Speech highlight the poor compliance practices widespread at private fund managers at the time, many of which likely persist among fund managers today. The first article in a two-part series analyzes the Division staff’s observations about the lack of resources, primitive information technology capabilities and marginalized CCOs at fund managers. The second article details the Risk Alert’s warnings about deficient annual reviews and ill-tailored policies, along with certain high-level takeaways to consider. See our two-part series on why fund managers must adequately support CCOs and compliance programs: “Recent Failures Lead to SEC Enforcement Action” (May 9, 2019); and “Six Valuable Lessons From Recent Enforcement Actions” (May 16, 2019).