10/19/2023 By Jared Calvert, Director, Compliance Services Changing leaves, cooler air, and pumpkin spiced lattes are not the only things investment advisers have to look forward to this fall. On October 16, 2023, the Securities and Exchange Commission (“SEC”) Division of Examinations released its exam priorities for 2024. This came eight short months after the…
By Lisa Ward, Director of Marketing Review and Matt Giggey, Director, Compliance Services As part of a sweep conducted by the Securities and Exchange Commission, charges were brought against nine registered investment advisers for advertising hypothetical performance to the general public on their websites without adopting and/or implementing policies and procedures required by the Marketing…
By Sarah Schmidt, Consultant On September 6th, 2023, the Securities and Exchange Commission (SEC) issued a risk alert titled, “Investment Advisers: Assessing Risks, Scoping Examinations, and Requesting Documents.” This seven-page document delves into the thought process behind examinations. It also includes attachments containing the typical examination procedures and document requests made by the SEC staff…
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…
Author: Alisha Dowell As we deal with current restrictions and personal distancing rules, it becomes more important than ever for investment advisory firms to connect with their clients and figure out how to best offer services moving forward. One way advisors are doing this is through replacing in-person meetings with video calls. While this new…
Author: Ashley Hatt In 2009, the SEC subjected advisors to a new list of Custody Rule requirements that sent the world of Registered Investment Advisors into a tailspin as they raced to understand the changes, how they affected their firm and how they could comply by the deadline. More than a decade and several additional…
Author: Alisha Dowell On April 7, 2020, the SEC Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert to provide information about initial examinations of SEC-registered broker-dealers and investment advisers (“firms”) taking place after the June 30 compliance deadline for the Form CRS. Firms must file their Form CRS client relationship summaries with…
Author: Ian Meiksins In a statement issued by SEC Chairman, Jay Clayton, the SEC announced it will not be extending the compliance date for the implementation of Regulation Best Interest (Reg BI) and Form CRS. The statement said that “because the continued implementation of these conduct and transparency initiatives, individually and collectively, will significantly benefit…
Author: Mike Spero The coronavirus pandemic was declared a national emergency on March 13, 2020. The pandemic’s rapid escalation has significantly altered public life globally, including forcing many businesses to close. To help our clients and colleagues prepare for and manage this ever-changing situation, we have put together the following list of items for investment…
End of content
End of content