By Kevin Kirk On March 30, 2022, the Securities and Exchange Commission’s (“SEC”) Division of Examinations (“Division”) released its 2022 Exam Priorities. The stated purpose for the Division in releasing these priorities is to promote compliance, prevent fraud, identify and monitor risk, and inform policy. The focus for the SEC in the coming year appears…
Job Description Key Bridge Compliance, LLC (Key Bridge) is seeking a Compliance Officer to join a growing team of driven, highly motivated compliance professionals. Key Bridge provides outsourced CCO and compliance services to Registered Investment Advisers. The compliance officer position will be responsible for working with senior staff and Chief Compliance Officers to implement and…
Job Description Key Bridge Compliance, LLC (Key Bridge) is seeking a Chief Compliance Officer (CCO) to join a growing team of driven, highly motivated compliance professionals. Key Bridge provides outsourced CCO and compliance services to Registered Investment Advisers. The CCO will be responsible for the implementation and ongoing oversight of the compliance program required by…
Washington, DC Key Bridge Compliance, LLC (Key Bridge) is seeking a Compliance Analyst to join a growing team of driven, highly motivated compliance professionals. Key Bridge provides outsourced CCO and compliance services to Registered Investment Advisers. The compliance analyst position will be responsible for working with senior staff and Chief Compliance Officers to implement and…
Author: Amy D’Avella This is the first in a series of blogs which will analyze the SEC’s Office of Compliance Inspections & Examination’s (OCIE) November 19 Risk Alert, titled OCIE Observations: Investment Adviser Compliance Programs.[1] I. Context Since requiring investment advisers to appoint Chief Compliance Officers (CCOs) in 2003[2], the SEC has treated CCOs as…
Coinciding with the SEC’s annual Compliance Outreach Program National Seminar, on November 19 the Office of Compliance Inspections & Examinations (OCIE) released a risk alert titled OCIE Observations: Investment Adviser Compliance Programs. This is the first risk alert in five years specific to Chief Compliance Officers (CCO), and comes at a time when compliance programs…
On November 9, 2010, the Securities and Exchange Commission’s Office of Examinations and Inspections released a risk alert titled Observations from OCIE’s Examinations of Investment Advisers: Supervision, Compliance and Multiple Branch Offices. With focus on compliance programs, supervision, and investment advice, OCIE performed examinations of 40 advisers, targeting the main office of each adviser and…
In the wake of an investigation by the Wall Street Journal showing that 20% of firms incorrectly stated having no disciplinary history in their Form CRS, the SEC updated its Form CRS FAQ on October 8 to clarify this particular reporting requirement. The FAQs illuminate questions 11 and 4 with the following: A firm must…
Author: Amy D’Avella Key Bridge Compliance has been made aware of a new phishing attack against both FINRA members and SEC-registered investment advisers. The phishing email appears to be sent from FINRA and attempts to elicit confidential firm information (see representative email below). We would advise all RIAs to delete emails sent from the domain…
Author: Amy D’Avella Accredited investors are those the SEC deems sufficiently sophisticated to operate in riskier investment environments, such as private markets. This definition has long been limited to select entities and individuals who meet certain net worth requirements. On August 26, 2020, the SEC finalized a much-anticipated change to the “accredited investor” definition, expanding…
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