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?
How Robust is Your Annual Review Process?
Federal regulations require investment advisers and registered investment companies to review their compliance policies and procedures annually to ensure adequacy. Core Compliance & Legal Services, Inc. recently published a Risk Management Update (“RMU”), which discusses Securities and Exchange Commission (“SEC”) … Read More
SEC Takes Advisory Firm to Enforcement for Failing to Deem a Third Party Consultant as an “Access Person”
In the Matter of Federated Global Investment Management Corp (“FGIMC”), the SEC settled an administrative proceeding against FGIMC for a failure to establish, maintain, and enforce written policies and procedures reasonably designed to prevent the misuse of material, nonpublic information … Read More
SEC Chair White Speech Outlines Future Areas of Regulatory Focus for Mutual Fund Industry
In a keynote address given to the Investment Company Institute during their 2016 General Meeting, the Securities & Exchange Commission (“SEC”) Chair Mary Jo White provided not only an overview of current areas of interest and proposals affecting mutual funds, … Read More
FINRA Rule 2210: Effective Date for Complying with Amendments
Amendment to FINRA Rule 2210
SEC Provides Clarification of Custody Rule
On April 25, 2016, the Securities and Exchange Commission’s (“SEC”) Division of Investment Management issued a no-action letter to the Investment Adviser Association (“IAA Letter”) giving relief to certain sub-advisers from surprise audits requirements under Rule 206(4)-2 under the Investment … Read More
SEC Held Compliance Outreach Program for Investment Advisers and Investment Companies
On April 19, 2016, the Securities and Exchange Commission (“SEC”) held their National Compliance Outreach seminar, which covered a number of topics, including: