Core Compliance Blog Spotlight

Don't Run Afoul of the All-or-Nothing Requirement of the SEC's New Marketing Rule

Many investment advisers eagerly await the new opportunities created by the SEC's New Marketing Rule. With a mandatory effective date of November 4, 2022, many advisers have begun to take steps to explore how they can change their marketing efforts today. To this end, an overwhelming number of... Read More
Core Compliance Blog Spotlight

SEC to Focus on Compliance Issues Related to Suspicious Activity Monitoring and Reporting at Broker-Dealers and Mutual Fund Firms

On March 29, 2021, the U.S. Securities and Exchange Commission ("SEC") Division of Examinations ("EXAMS") issued a Risk Alert citing frequent shortcomings found in compliance reviews of Anti-Money Laundering (AML) reporting at broker-dealer and mutual fund firms. Find the Risk Alert here. Read More

Steps Advisers and Investors Can Take to Protect Against Potentially Fraudulent Investments in a Post-Madoff World

March 12, 2021

Almost 12 years have passed since Bernie Madoff was sentenced to 150 years in prison with a restitution of $170 billion for perpetrating an elaborate Ponzi scheme that harmed thousands of clients. Widely regarded as the largest fraudulent investment scandal in U.S. history, the Madoff case...

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Timely Takeaways from Zoom’s Consent Agreement with the FTC over Data Management Practices

March 08, 2021

Firms should take note that information security will remain an area of intense focus this year for the U.S. Securities and Exchange Commission’s (SEC) Division of Examinations (the Division or EXAMS), formerly known as the Office of Compliance Inspections and Examinations (OCIE).

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What Investment Advisor Reps Need to Know About New York State’s New Registration Requirements

February 12, 2021

The Investor Protection Bureau (IPB) of the New York State Attorney General’s office has adopted regulations that took effect February 1, 2021, under which investment advisor representatives (IARs) of both federal and state investment advisory firms must register with the state and meet certain...

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Reminder of March 1 NFA Deadline for CPOs and CTAs to Reaffirm Exemption Status

February 08, 2021

Every new year brings a multitude of filings that compliance officers of financial advisory firms must make to meet regulatory requirements. Among the items on the compliance checklist for those involved in futures trading is the annual need to reaffirm their Commodity Futures Trading Commission...

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SEC Provides Long-Awaited Guidance and Requests Comments to Help Protect Bitcoin Investors

January 19, 2021

When the price of a much-publicized asset increases 296% as Bitcoin did in 2020, it’s bound to attract attention from institutional investors, the general public, and the U.S. Securities and Exchange Commission (SEC).

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Record Market Trading Volume in 2020 Could Prompt Your Firm’s Need to File SEC Form 13H

January 14, 2021

The global COVID-19 pandemic has changed the way many of us live, work, and invest. Trading activity in global and domestic markets spiked last year, partly as a result of the added time millions spent at home to avoid exposure to the coronavirus.

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NASAA Members Adopt Model Rule to Require Continuing Education by Investment Adviser Representatives

December 15, 2020

The North American Securities Administration Association (NASAA) is a voluntary body composed of state securities regulators across all 50 states, Canada, and Mexico. Founded in 1919, it is the oldest international regulatory organization devoted to investor protection.

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Helpful Hints on What to Expect in 2021 from the SEC’s Division of Enforcement: No One is Above the Law

December 10, 2020

Closing out our short series of suggested focus areas for 2021, this blog post focus on the overall theme of the SEC's Division of Enforcement’s Annual Report. Over the course of 2020, the industry has tried to navigate through unknown territory, striving to serve their clients, keep their...

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