Core Compliance Blog

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...

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...

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...

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.

At the end of August, the Securities and Exchange Commission (“SEC”) issued a release amending a number of rules under the Investment Advisers Act of 1940 (“Advisers Act”), as well as Form ADV, which is the registration and reporting form for investment advisers.  The SEC outlined in their release...

On August 15, 2016, the National Futures Association (NFA), the self-regulatory organization for the U.S. derivatives industry, made revisions to its Self-Examination Questionnaire that is required to be completed annually by Financial Commission Merchants (FCMs), Forex Dealer Members (FDMs),...

On August 10, 2016, the SEC filed a complaint in federal court against Merrill Robertson Jr., a former Philadelphia Eagles football player, with defrauding investors.  Mr. Robertson, along with Sherman C. Vaughn, Jr., and the company they co-owned, Cavalier Union Investments LLC, allegedly promised...

Since 2014, the Securities and Exchange Commission (“SEC”) has been talking about proposing requirements for SEC registered investment advisers to obtain third party compliance reviews.  The more recent being in Chairman Mary Jo White’s testimony given to the U.S. Senate Subcommittee on Financial...

On May 11, 2016, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule on customer due diligence (the “CDD Rule”).  This rule addresses new and existing due diligence requirements for Covered Financial Institutions (as defined in the rule), which include banks, broker-dealers,...

The Securities and Exchange Commission (“SEC”) recently issued proposed Rule 206(4)-4 under the Investment Advisers Act of 1940, as amended (“Advisers Act”), requiring registered investment advisers to have written plans addressing business continuity and transition (wind down) steps in the event...