Core Compliance Blog Spotlight

Top 3 Considerations for Conducting an Annual Review

Under Rule 206(4)-7 (“Compliance Rule”) of the Investment Advisers Act of 1940 (“Advisers Act”), Investment Advisers (“RIAs”) that are registered with the Securities and Exchange Commission (“SEC”) must perform an annual review of the RIA’s policies and procedures (“P&Ps) to “test their adequacy... Read More
Core Compliance Blog Spotlight

NFA Permanently Bars Hong Kong Futures Firm

On June 1, 2020 the National Futures Association (“NFA”) permanently barred Hong Kong-based commodity pool operator Bainbridge Asia Limited (“BAL” or the “Firm”) and its sole principal and associated person, Wai Man Yip, from membership and acting as a principal of an NFA member on the basis of a... Read More

SEC Charges Private Equity Firm with Compliance Failures

June 05, 2020

On May 26, 2020, the Securities and Exchange Commission (“SEC”) announced that Los Angeles-based private equity firm and registered investment adviser, Ares Management LLC (“Ares” or the “Firm”) agreed to a cease-and-desist order, censure, and to pay a $1 million fine to settle charges that it...

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FINRA Updates Web CRD and IARD Security with Multi-Factor Authentication

May 21, 2020

The Financial Industry Regulatory Authority (“FINRA”) has upgraded the Web Investment Adviser Registration Depository (“IARD”) and Central Registration Depository (“CRD”) to include multi-factor authentication (“MFA”) in an effort to make the websites more secure:

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FINRA and Prometric Provide Updates on Online Testing and Test Center Solutions

May 15, 2020

The Financial Industry Regulatory Authority (“FINRA”) and Prometric Testing Centers have announced additional accommodations and updates for individuals seeking to take exams for the Securities Industry Essentials (“SIE”) and Series 6, 7, 65, 66, and 63 Exams, and fulfillment of continuing...

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New Guidance on COVID-19 Relief Relating to PPP Loan Eligibility, Form ADV Brochure Delivery, and more

May 06, 2020

On April 27, 2020, the Securities and Exchange Commission’s Division of Investment Management (the “SEC”) issued updated guidance concerning the following topics in response to COVID-19:

  • Disclosure requirements for investment advisers applying for loans through the U.S Small Business...
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MSRB Extensions of Deadlines during COVID-19 Pandemic

April 27, 2020

Due to the considerable operational obstacles faced by many entities under their regulatory umbrella due to COVID-19, the Municipal Securities Rulemaking Board (MSRB) has filed a rule change to provide regulatory relief by extending the compliance and testing deadlines for certain MSRB rules and...

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Compliance with Form CRS Requirements: OCIE Announces Examination Priorities

April 21, 2020

On June 5, 2019, the Securities and Exchange Commission (SEC) adopted Form CRS under both the Securities Exchange Act of 1934 and the Investment Advisers Act of 1940, with a compliance deadline of June 30, 2020.

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Want to Advertise to Help Differentiate Your Firm? Read This First

April 14, 2020

Ask chief compliance officers what keeps them up at night and you’ll find the approval of marketing materials, social media communications, and other forms of advertising rank high on the list.

Two factors have combined to cloud best practices for investment advisers who want to advertise, a...

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SEC Reduces Regulatory Burdens for Advisers of RBICs

April 07, 2020

On March 2, the U.S. Securities and Exchange Commission took two important steps to alleviate red tape for investment advisers who provide capital to and work with Rural Business Investment Companies (RBICs).

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