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

SEC Fined 10 Firms for Violating Pay-to-Play Rule

February 16, 2017

In June 2010, the SEC adopted the Rule 206(4)-5 of the Investment Advisers Act of 1940, which addressed “pay-to-play” practices surrounding political contributions.  Pay to play is a term used in the financial industry that generally refers to investment advisers making campaign contributions to...

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SEC Examination Priorities for 2017

January 26, 2017

Examination Priorities

Each year the SEC Office of Compliance Inspections and Examinations publishes their SEC examination priorities letter to inform the industry of their current focus areas.  The 2017 letter was released on January 12, 2017, and is available on the SEC’s website.  The letter...

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California Attorney Defrauds EB-5 Investors

January 25, 2017

On December 27, 2016, the Securities & Exchange Commission (“SEC”) charged Emilio Francisco with defrauding investors seeking to participate in the EB-5 immigrant investor program. The EB-5 program, which is administered by the U.S. Citizenship and Immigration Service (“USCIS”), allows foreign...

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FINRA Announced Its 2017 Exam Priorities

January 13, 2017

According to Robert W. Cook, since becoming the president and CEO of FINRA in August 2017, he has “been engaged in an ongoing ‘listening tour’ meeting with member firms, regulators and investor groups, among others.”  In the cover letter he issued announcing the release of FINRA’s 2017 Regulatory...

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End of Year is Almost Here – Are You Prepared?

December 19, 2016

2016 is speeding to a close, so to assist advisory firms in preparing for year-end compliance requirements, along with certain upcoming regulations, CCLS recently published a Risk Management Update (“RMU”) that contains a year-end compliance checklist.  While it’s not all inclusive, the checklist...

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The Next Iteration of Fraudulent Disbursements

December 15, 2016

Criminal activity is constantly evolving.  Fraud emanating from a compromised email account is fairly well known and most firms have implemented authentication procedures to address fraudulent third-party wire transfers.  However, another threat has recently gained traction in the financial...

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Mary Jo White Stepping Down as Chair of Securities and Exchange Commission

November 17, 2016

On November 14, 2016, Mary Jo White, SEC Chair, announced her plans to step down at the end of the Obama Administration. During her tenure, the SEC brought more than 2,850 enforcement actions and obtained judgements and orders that tallied more than $13.4 billion in monetary sanctions. Although...

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Department of Labor Issues First Set of FAQs on DOL Fiduciary Rule

October 31, 2016

On October 27, 2016, the DOL issued highly anticipated guidance on the Conflicts of Interest Rule in the form of FAQs that address the exemptions.  The Director of the Employee Benefits Security Administration (“EBSA”), Phyllis Borzi, indicated this is the first of three sets of FAQs and the second...

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Don’t Get Too Close: Auditor Independence Failures Result in SEC Enforcement Actions

September 22, 2016

Recently, the London-based public accounting firm Ernst & Young, along with a senior partner and an auditor agreed to pay approximately $9.3 million in settlement charges after SEC investigations determined that there had been violations of auditor independence rules.  According to the news release...

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SEC Sweep Results in 13 Enforcement Actions Against Advisers for Advertising a Third-Party’s False Performance Claims

September 20, 2016

On August 25, 2016, the SEC issued press release 2016-167 detailing the results of an enforcement sweep leading to settlements with thirteen investment advisers for advertising a third-party’s false performance claims.

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