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The Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (“ OCIE”) highlighted alternative data, or “alt data,” as a top examination priority. 1  AIMA held a webinar on November 17, 2020, for investment managers on OCIE’s use of alt data, entitled Alternative Data and OCIE: How, What and Why You Should Prepare Ahead of Your Next SEC Exam, led by Senior Advisor of Promontory Financial Group Jane Jarcho, Director of Promontory Financial Group Sarah Curran, Director of Promontory Financial Group Drew Weilbacher, as well as AIMA’s Senior Advisor, Suzan Rose. 1.  Scrutinize Your Information Sources The first takeaway is to scrutinize your information sources to identify your use of alt data providers, in particular, and how that data fits into the firm’s policies and procedures in relation to material nonpublic information (“

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