June 2, 2021 CCO Liability: Do you have a target on your back? When the SEC set out to require registered investment advisers to implement a compliance program and designate a chief compliance…
May 5, 2021 The New Marketing Rule – Develop Your Plan The new Marketing Rule (Rule 206(4)-1 under the Investment Advisers Act of 1940) is effective on May 4, 2021, starting…
March 29, 2021 SEC Releases 2021 Examination Priorities On March 3, 2021, the SEC’s Division of Examinations (“Division”) released their examination priorities (“Release”) for 2021. The Release represents…
February 11, 2021 Groundhog Day for Compliance & the SEC in 2021 It’s almost mid-February, and we’ve come out of the January haze. Now we have a bit more information on where…
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…
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,…
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…
September 2, 2020 The SEC Amends the Definition of “Accredited Investor” and the Debate Over Private Market Protections Continues On August 26, 2020, the Securities and Exchange Commission amended Rule 501(a) of the Securities Act of 1933, expanding the…
August 12, 2020 Breakdown of OCIE’s COVID-19 Compliance Risks Alert The SEC’s “Office of Compliance Inspections and Examinations (“OCIE”) issued an Alert today regarding “Select COVID-19 Compliance Risks for Investment…
July 30, 2020 SEC’s New Committee Begins Review of Form CRS Filings The SEC’s Divisional Standards of Conduct Implementation Committee launched its review of Form CRS from a cross section of RIAs…
July 14, 2020 Proposed Amendment to 13F – What This Really Means? The SEC released a proposed amendment to Form 13F on July 10 to update the reporting threshold for institutional investment…