Core Compliance Blog Spotlight

Disclosure Improvements Proposed by SEC for Variable Annuities and Variable Life Insurance Contracts

In an Oct. 30, 2018, press release, the Securities and Exchange Commission (SEC) has announced that a proposal for updated disclosure agreements involving the complicated arena of variable annuities and variable life insurance contracts has been approved for public comment. Read More
Core Compliance Blog Spotlight

FTC Develops Cybersecurity Education Program

Cyberattacks pose a very real threat to all modern businesses, from massive corporate conglomerates to smaller local establishments, causing ever greater financial losses and increased headache each year for all who are affected. Read More

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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SEC Amends Rules Under Investment Advisers Act

September 09, 2016

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...

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NFA Updates to Self-Examination Questionnaire

August 23, 2016

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),...

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SEC Files Complaint Against Former Professional Football Player

August 15, 2016

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...

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What to Expect When the SEC Proposes Requirements for Advisers to Obtain Third Party Compliance Reviews

August 04, 2016

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...

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FinCEN Issues FAQs Pertaining to their Final Rule Under the Bank Secrecy Act

July 29, 2016

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,...

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SEC Says Investment Advisers Need to Think About Transition Planning

July 20, 2016

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...

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