March 10, 2020 SEC Continues Scrutiny of Private Fund Cross Trades The SEC continues to scrutinize principal and cross-trade transactions in the private fund world. Are such trades illegal? No. In…
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…
May 7, 2019 Refreshing the Annual Review Process to Address Business and Regulatory Risks Rule 206(4)-7 requires each registered adviser to review its policies and procedures no less frequently than annually, to determine their…