January 4, 2021 Brexit – A Free Trade Deal, Yet the Saga Continues The UK and EU have finally agreed to terms on Brexit that will likely lead to ratification of an historically…
December 22, 2020 SEC Adopts Changes to Marketing and Cash Solicitation Rule Frameworks In late 2022, SEC registered investment advisers will be required to comply with new marketing and client solicitation rule-making, adopted…
December 2, 2020 CSS Hosts OCIE Director Pete Driscoll for a Virtual Fireside Chat SEC’s Office of Compliance Inspections and Examinations Cites Inadequate Compliance Programs On December 1, 2020, CSS hosted a discussion with…
November 30, 2020 The Moving Target of ESG Regulation in the EU ESG – the integration of environmental, social and governance considerations into the investment process – has claimed center stage in…
November 18, 2020 Form CRS “Fiduciary” Guidance Received by IAA in June 2019 Still Valid Since the compliance date of Form CRS over four months ago, the SEC has reviewed forms filed by registered investment…
October 30, 2020 Time to Use the Bat Phone: Who to Call When a Compliance Officer Needs Help? It seems that the burden of work continues to increase for compliance professionals in the investment management industry. While also…
October 12, 2020 Texas Outlaws and a Silver Bullet: Position Limits in the USA In this first installment on position limits, Regulatory Guidance expert Greg Hotaling surveys the current landscape of position limits imposed…
October 12, 2020 FAQs From the Cyber Desk Cybersecurity is a fast-moving target, so it is not uncommon for firms to have questions when it comes to assessing…
October 12, 2020 EU Position Limits: Born in the USA? This is the second installment of Regulatory Guidance Expert Greg Hotaling’s blog on position limits, this time addressing EU-listed commodity…
October 12, 2020 Double-Check the Disciplinary Response in Form CRS, Especially Checking Histories of Financial Pros On October 8, 2020 the SEC published updated FAQs regarding the disciplinary question in Form CRS. In an unusual step,…
October 2, 2020 First Charges Filed Under NYDFS Cybersecurity Regulations On July 21, 2020, The New York State Department of Financial Services (NYDFS) filed its first charges under its Cybersecurity…
September 25, 2020 From One CCO to Another: Don’t Lie to the SEC Every once in a while, I think it’s important to get back to the basics. Since the adoption of the…