Core Compliance Blog Spotlight

SEC Proposes Amendments to OTC Securities Quotations

Over the past several years, The Securities and Exchange Commission (“SEC”) has brought hundreds of enforcement actions over violations of federal securities involving over-the-counter (OTC) securities, resulting in tens of millions in harm to retail investors. In an effort to increase retail... Read More
Core Compliance Blog Spotlight

SEC Charges Investment Advisers for Failing to Disclose Conflicts of Interest

Strategic Planning Group (“SPG”) agreed to settle charges with The Securities and Exchange Commission (“SEC”) for failing to disclose a conflict of interest by consenting to a cease-and-desist order, censure, and civil penalties of $200,000. Its principals, David A. Rourke and Jarrod A. Sherman... Read More

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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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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