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Enhancing Annual Reviews – Practical Considerations for Investment Advisers and Investment Companies

It’s been over a decade since the Securities and Exchange Commission (“SEC”) adopted Rule 206(4)-7 under the Investment Advisers Act of 1940, and Rule 38a-1 under the Investment Company Act of 1940. Despite the passage of time, Rule 206(4)-7 and … Read More

SEC Fines Firm for Failure to Adopt Cybersecurity Policies and Procedures

Recently the Securities and Exchange Commission (“SEC”) charged a St. Louis Investment adviser that had experienced a breach of client non-public information with failing to create and implement cybersecurity policies and procedures. According to the SEC’s press release, for over … Read More

FinCEN Proposed Rule to Prescribe Standards for Anti-Money Laundering Programs

On August 25, 2015, the Financial Crimes Enforcement Network (“FinCEN”), a bureau of the Department of Treasury (“Treasury”), proposed a rule that would “prescribe minimum standards for anti-money laundering programs (“AML”) to be established by investment advisers.” This rule would … Read More

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