On November 9, 2021, the U.S. Securities and Exchange Commission (SEC) Division of Examinations (EXAMS) released a risk alert (Risk Alert) concerning deficiencies it observed in its examinations of advisers providing electronic advisory services, including advisers known as “robo-advisers.”¹ Those deficiencies were in the areas of the robo-advisers’ compliance programs, portfolio management practices (including advisers’ fiduciary obligations), and marketing/performance advertising. (more…)