August 31, 2020 The Lasting Impact of COVID-19 on Investment Management The COVID-19 pandemic and related shutdown of global economies will be remembered as one of the most significant shocks to…
May 29, 2020 Don’t Forget the Disclosure Obligation Recently, the SEC announced the settlement of an enforcement case against Morgan Stanley Smith Barney (MSSB) involving charges that MSSB…
April 23, 2020 Eventually, We Have to Go Back – BCP Post-Mortem We don’t know when, but at some point we will have to put on shoes, get a haircut and return…
January 17, 2020 Compliance Lessons Learned in 2019 Now that we are in mid-January, a few things are evident. We have likely broken one or more New Year’s…
September 6, 2019 SEC Issues Guidance to Investment Advisers on Proxy Voting At its August 21, 2019 Open Meeting, the Securities and Exchange Commission (“SEC”) voted 3-2 to issue guidance to assist…
September 4, 2019 Regulation Best Interest: Understanding the Obligations We have been conducting roundtables and talking to industry leaders to help them identify the challenges that broker-dealers will face…
May 9, 2019 Life Cycle Guidance for Service Provider Due Diligence Engaging third-party service providers to perform key functions can offer an investment adviser access to state-of-the-art technology and solutions necessary…
April 29, 2019 Mitigating the Risk of Insider Trading One of the biggest risks affecting investment advisers is the potential that material non-public information (“MNPI”) may be misused, leading…
October 12, 2018 It Takes a Village – Preparing for a Regulatory Exam Advanced planning for a regulatory exam remains a vital step in ensuring the compliance team is prepared when the exam…