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…
September 2, 2019 Cannabis Cash & Federal Taxes – A Proprietary Process In order to pay federal taxes, many licensed, regulated, cannabis companies have to launder their cash. Why? Because banks will…
August 27, 2019 Short-Termism, the EU Shareholder Rights Directive, and Their Relevance to Shareholder Disclosure Recent consultative processes in Europe and the United States reflect the interest being shown by regulators around the world in the problem of “short-termism” in capital markets.
August 20, 2019 Effective Compliance Policies & Procedures and Annual Reviews: Meeting the Reasonably Designed Standards Sometimes it seems that enough is never really enough. While compliance officers have grown intimately familiar with SEC Rule 206(4)-7…
August 7, 2019 7 Reasons to Attend Our Scottsdale Fall 2019 Compliance Conference If you’ve been considering joining us in Scottsdale for our Sept. 23-25 compliance event, here are seven reasons you should…
July 31, 2019 Refocusing on Position Limit Monitoring & Substantial Shareholding In recent months, we have begun to offer roundtable events focusing on important, evolving topics within the compliance world.
July 25, 2019 Serious Security Flaw Discovered in Three Widely Used VPNs – Update Now! Virtual Private Networks (“VPNs”) are a secure way for employees to access firm files remotely, whether working from a home…
July 22, 2019 The Challenges of Compliance for State-Registered Advisers Are you the designated chief compliance officer of a state-registered investment advisory firm? If so, you must be clocking many…
July 9, 2019 How Can a Small Advisory Practice Economically Be as Cyber-Secure as Possible? Cybersecurity is a risk that applies to firms both large and small without discrimination. Even very small advisory firms, which…
July 8, 2019 Will We See Liquidity Risk Management Programs in Europe Soon? In an article posted by Ignites Europe, the Commission de Surveillance du Secteur Financier (CSSF) in Luxembourg declared that it…
July 2, 2019 How an LPA’s Definition of Organizational Expenses Can Connect to a Custody Rule Violation For private fund advisers, fee and expense reviews are a cornerstone to a sound compliance program. The SEC repeatedly reinforces…