September 15 , 2016 – Wolters Kluwer Modern Compliance
CEO, Michelle Jacko and consultant Tina Mitchell will be presenting: Chapter on Due Diligence.
FinCEN Issues FAQs Pertaining to their Final Rule Under the Bank Secrecy Act
On May 11, 2016, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule on customer due diligence (the “CDD Rule”). This rule addresses new and existing due diligence requirements for Covered Financial Institutions (as defined in the rule), which … Read More
SEC Proposed Business Continuity & Transition Plan Rule: More than Just Disaster Recovery Planning
On June 28, 2016, the Securities and Exchange Commission (“SEC”) issued a proposal requiring SEC registered investment advisers to implement a written business continuity and transition plan (“BCTP”).1 In the corresponding press release,2 the SEC stated that the purpose of the … Read More
SEC Says Investment Advisers Need to Think About Transition Planning
The Securities and Exchange Commission (“SEC”) recently issued proposed Rule 206(4)-4 under the Investment Advisers Act of 1940, as amended (“Advisers Act”), requiring registered investment advisers to have written plans addressing business continuity and transition (wind down) steps in the … Read More
SEC Alerts Registered Advisers About Share Class Exam Initiative
On July 13, 2016, the Securities and Exchange Commission (“SEC”), through their Office of Compliance Inspections and Examinations (“OCIE”), issued a Risk Alert outlining their exam initiative on risks and conflicts pertaining to investment adviser recommendations of mutual funds and … Read More
The Investment Advisers Modernization Act of 2016
On June 16th, the House Financial Services Committee approved H.R. 5424, the “Investment Advisers Modernization Act of 2016.” The proposed bill primarily provides relief to private fund advisers, but also includes provisions applicable to investment advisers that don’t manage private … Read More
The DOL Conflicts of Interest Rule and How it May Affect You (Part 2)
Who is an ERISA Fiduciary?