Core Compliance Blog Spotlight
Core Compliance Blog Spotlight
What CCOs and Compliance Departments Need to Know About the SEC’s New Definition of ‘Accredited Investor’
Not long ago, the ability to invest in private offerings in the U.S. was limited to those whose annualized income and net worth afforded a country-club lifestyle. The requirements were an average income of $200,000 for the last two years ($300,000 for joint income) and/or a net worth of $1 million,... Read MoreYour Annual Review: Cybersecurity and Privacy
September 09, 2020
The annual review is one of the three (3) pillars of Rule 206(4)-7 (“the Compliance Rule”) of the Investment Advisers Act of 1940 (“the Advisers Act”).
Read MoreInteractive Brokers, LLC to Pay Penalties for Failure to File Suspicious Activity Reports
August 19, 2020
On August 10, 2020, the Securities and Exchange Commission (“SEC”) announced that Interactive Brokers, LLC (“IB” or the “Firm”) had agreed to pay $11.5 million in fines for failure to file Suspicious Activity Reports (“SARs”) in conjunction with trading micro-cap securities on behalf of its...
Read MoreSEC Charges Birinyi Associates, Inc. with Unfair Trade Practices and Compliance Failures
August 19, 2020
On July 31, 2020, the Securities and Exchange Commission (“SEC”) announced it was charging Connecticut-based investment adviser, Birinyi Associates, Inc. (“BA” or the “Firm”), with violations of Sections 206(2) and 206(4) and Rule 206(4)-7 thereunder (“the Compliance Rule”) of the Investment...
Read MoreSEC Charges Valic Financial Advisors in Two Separate Actions with Disclosure Failures and Mutual Fund Selection Violations
August 07, 2020
On July 28, 2020, the Securities and Exchange Commission (“SEC”) announced it was charging Houston-based financial services firm, Valic Financial Advisors, Inc. (“VFA” or the “Firm”), a dually-registered broker-dealer and investment adviser, in two separate actions for violations of Section...
Read MoreOn July 10, 2020, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (“OCIE”) released a risk alert highlighting a recent increase in ransomware attacks against financial industry participants.
Read MoreNASAA Released Proposed Model Compliance Rule
July 16, 2020
On July 2, 2020, the North American Securities Administrators Association (“NASAA”) released a notice for public comment on its proposed model rule for investment adviser written policies and procedures (“the Model Rule”) under the Uniform Securities Acts of 1956 and 2002 (“the Acts”).
Read MoreDOL Proposes New Class Exemption Rule
July 09, 2020
On June 29, 2020, the U.S. Department of Labor (DOL) proposed its new class exemption rule (the “Rule”) designed to replace the 2016 Best Interest Rule that was vacated by the U.S. Court of Appeals for the Fifth Circuit (“the Fifth Circuit”) in 2018.
Read MoreTop 3 Considerations for Conducting an Annual Review
June 16, 2020
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...
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