October 7, 2019 Can We Say That Now? Predictions on Marketing and Advertising Amendments Can we say that now? That’s what attendees at the recent CSS Compliance Conference in Scottsdale, Arizona wanted to find…
September 19, 2019 Improving Mutual Funds’ Principal Risks Disclosure The Securities and Exchange Commission (SEC) has for years stressed that registrants’ disclosure in regulatory filings needs to be written…
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 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…
May 24, 2019 SEC Begins Cyber Sweep of Investment Advisers with Focus on Cloud Storage A sweep of investment advisers is underway by the U.S. Securities and Exchange Commission, which has sent out many letters…
May 8, 2019 Takeaways and Tips Related to SEC Risk Alert on Regulation S-P On April 16, 2019, the SEC released a Risk Alert providing a list of compliance issues related to Regulation S-P,…
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…
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…
January 28, 2019 SEC Reopened After 35-Day Government Shutdown SEC Chairman Jay Clayton announced on Saturday, January 26 that with an agreement reached to end the government shutdown, the “Commission…
December 21, 2018 SEC OCIE Issues 2019 Examination Priorities Well ahead of the New Year, the SEC Office of Compliance Inspections and Examinations (OCIE) announced its 2019 examination priorities….
August 28, 2018 When Policies, Procedures and Testing Protocols Aren’t Enough… The Compliance Program Rule continues to be a powerful tool for SEC enforcement, recently used by the SEC to address…
July 27, 2018 How Do You Supervise for SEC Pay-to-Play Violations? If you wanted more information about the contours of the SEC’s Pay-to-Play Rule, or how the SEC may enforce it,…