Core Compliance Blog Spotlight

Updating Your Cybersecurity Policy: NFA Releases Interpretive Notice 9070

Our ever-increasing reliance on electronic devices and information technology to do business, combined with the constantly evolving methods used to electronically attack our firms and our clients, has elevated information security (cybersecurity) into a position of great importance. Read More
Core Compliance Blog Spotlight

OCIE 2019 Examination Priorities Released

In a December 2018 press release, the SEC (Securities and Exchange Commission) announced the publication of the OCIE (Office of Compliance Inspections and Examinations) examination priorities for 2019. Read More

Nevada Creates Own Fiduciary Rule

July 19, 2017

Recently, Nevada Governor Brian Sandoval signed into law Senate Bill 383 that revised current regulations for financial planners. The changes expand the definition of financial planner in NRS 628A.010 to now include broker-dealers and investment advisers in Nevada, which in turn requires such...

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SEC Seeks Public Comment on Standards of Conduct for Investment Advisers and Broker-Dealers

June 16, 2017

In a recent public statement, Securities and Exchange Commission (“SEC”) Chairman Jay Clayton announced that the SEC is moving forward with its review of the standards of conduct mandates for investment advisers and broker-dealers and he welcomes the Department of Labor (“DOL”) Secretary...

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Time’s Up: The Fiduciary Rule Delay Comes to an End

May 24, 2017

Originally intended to go into effect on April 10, 2017, the DOL’s Conflicts of Interest final rule (referred to in the industry as the “Fiduciary Rule”) was delayed for 60 days while the department analyzed issues raised in President Trump’s February 3, 2017, memorandum. Despite the...

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SEC Issues Risk Alert on Cybersecurity in Light of “WannaCry” Ransomware Attack

May 18, 2017

On May 17, 2017, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) released a Risk Alert discussing the recent ransomware cyberattack and providing two important protection steps firms should take.  In addition, the Risk Alert outlined that OCIE had observed certain “security...

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High Profiled Risks Associated With Investment Advisory Firms

May 15, 2017

The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) has been issuing written Risk Alerts since 2011 that outline areas the SEC believes carry high risks for broker-dealers and investment advisers.  The areas covered in these alerts have included:

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“SEC Expectations for Managing Retirement Accounts” Webinar Q&A

May 01, 2017

In April, Craig Watanabe, Sr. Compliance Consultant at Core Compliance & Legal Services, Inc. (“CCLS”), hosted an informative webinar, “SEC Expectations for Managing Retirement Accounts.” During the presentation, he discussed important considerations for the now delayed DOL Conflicts of Interest...

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Applicability Date of Fiduciary Rule Delayed

April 17, 2017

On April 4, 2017, the Department of Labor (“DOL") issued a news release announcing that they are extending the applicability date of their Conflicts of Interest Rule (commonly referred to as the "Fiduciary Rule”) for 60 days.  The release also extends the applicability dates of related exemptions,...

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DOL Issues Bulletin in Wake of Proposed Rule Delay

March 23, 2017

Following the proposed rule to delay the Department of Labor’s Conflicts of Interest Rule (the “DOL Rule), John Canary, the DOL’s Director of Regulations and Interpretations, issued a Field Assistance Bulletin announcing a temporary enforcement policy. This memorandum, which was sent to the...

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No-Action Letter on Custody Pertaining to Standing Letters of Authorization

March 10, 2017

As a result of widespread confusion and uncertainty among investment advisers and other members of the financial industry, the Investment Adviser Association (IAA) sent a letter to the SEC’s Division of Investment Management requesting clarification and no-action relief pertaining to written...

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Preparing for SEC Exams: Top Five Identified Deficiencies by the OCIE

March 02, 2017

In February 2017, the Securities and Exchange Commission (“SEC”) published a Risk Alert highlighting the top five most common compliance topics identified in deficiency letters issued to SEC registered investment advisers (“RIA”).

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